BLM LIBRARY
8801:
U.S. DEPARTMENT OF THE INTERIOR
Bureau of Land Management
Final
Oregon State Office
May 1983
Roseburg
Timber Management
Environmental
Impact Statement
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IN REPLY
REFER TO:
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Roseburg District Office
777 N.W. Garden Valley Blvd.
Roseburg, Oregon 97470
1792
May 27, 1983
This is the final environmental impact statement (FEIS) on the 10-year timber
management plan for the Douglas and South Umpqua Sustained Yield Units in the
Roseburg District. The purpose of the statement is to disclose the probable
environmental impacts and to assure that these impacts are considered along
with economic, technical and other factors in the decisionmaking process. In
using this analysis, readers should keep in mind that a FEIS is not the
decision document. A final decision will ccme later and will be announced in
a Record of Decision.
A major issue of BIM's timber management throughout western Oregon has been
concern regarding which uses of the forest land base were authorized under
the terms of the O&C Act and subsequent legislation. In March 1983,
following a major legal review and analysis of these authorities, BLM
Director Robert Burford issued a new O&C Forest Resources Policy defining the
agency position for the management of forest lands in western Oregon. The
proposal developed from application of the policy (see Appendix A) is
identified in the statement as the New Preferred Alternative (Alternative 9).
This EIS is being released in accordance with a schedule contained in the
agreement of February 19, 1976, relative to the litigation in the U.S.
District Court for the District of Columbia, entitled Natural Resource
Defense Council, Inc., et al . v. Thomas S. Kleppe, et al. , Civil No. 75-1861.
Due to the addition of a New Preferred Alternative (Alternative 9), a 60-day
comment period on the FEIS is established. Comments received by the Roseburg
District before August 1, 1983 will be considered prior to the release of a
Roseburg Record of Decision.
Sincerely yours,
l> James E. Hart
District Manager
Bureau of Land Management
Library
Bldg. 50. r ~ ral Center
Oenver, CO 80225
0123-^
S3
U.S. DEPARTMENT OF THE INTERIOR
Bureau of Land Management ^ ~J
BUi Library ~ §> g
D-653A, Buildirg50
Denve fi ec - al canter
P.O. Bcxi,6o47
Denver, CO 80225-0047
FINAL
ENVIRONMENTAL
IMPACT STATEMENT
Roseburg
Sustained Yield Units
Ten-Year
Timber Management Plan
eauofU.
UbjW Cen ter
Denver, CO 80225 ^
Prepared By
U.S. DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
1983
State Director, Oregon State Office
Roseburg Proposed Timber Management
VICINITY MAP
ROSEBURG SYUS
Draft ( ) Final (x) Environmental Impact Statement
Department of the Interior, Bureau of Land Management
1. Type of Action: Administrative (x) Legislative ( )
2. Abstract: This EIS describes and analyzes the environmental impacts of implementing an updated 10-year
(1984-1993) timber management plan for the 423,896 acres of public land in the Douglas and South Umpqua
Sustained Yield Units in the Roseburg District, Oregon. The Bureau of Land Management is responsible for
managing timber on public lands under the principle of sustained yield. Nine alternatives are described and
analyzed for environmental impacts. The alternatives analyzed include: 1) Maximum Timber Production, 2)
Strong Emphasis on Timber Production, 3) Lower Average Minimum Harvest Size, 4) the Original Proposed
Action, 5) No Action, 6) Habitat Diversity, 7) No Herbicides, Fertilizer or Allowable Cut Effect for Genetics,
8) Emphasis on Protection of Natural Values, 9) New Preferred Alternative. Specific timber management
components of the alternatives include road construction, timber harvest, site preparation, reforestation,
plantation protection, precommercial thinning, fertilization and control of competing vegetation.
Significant environmental impacts of the New Preferred Alternative include wildlife habitat modification;
soil erosion, landsliding and stream sedimentation; and increased timber harvest and employment.
3. Due to the addition of a New Preferred Alternative, a 60-day comment period on the FEIS is established.
Comments will be accepted by the Roseburg District Manager until August 1, 1983, at the address listed
below.
4. For further information contact:
Bob Alverts, Planning Coordinator
Bureau of Land Management
Roseburg District Office
777 NW Garden Valley Blvd.
Roseburg, Oregon 97470
Telephone (503) 672-4491
Summary
Introduction
This environmental impact statement (EIS)
describes and analyzes the environmental impacts
of implementing an updated 10-year (1984-1993)
timber management plan for the Douglas and
South Umpqua Sustained Yield Units in the
Roseburg District, Oregon. Hereafter, the
Sustained Yield Units will be referred to as the
Roseburg Sustained Yield Units or simply the
SYUs. This EIS applies to actions proposed for the
423,896 BLM-administered acres within the
combined SYUs. These are primarily revested
Oregon and California Railroad (O&C) lands and
reconveyed Coos Bay Wagon Road (CBWR) lands.
There are also scattered remnants of the original
Public Domain (PD) lands.
Approximately 402,000 acres of the land area in
the Roseburg SYUs is commercial forest land, with
an additional 21,900 acres in non-commercial
forest or non-forest categories. To the extent
possible, non-forest, non-intensive commercial
forest land and withdrawn areas have been used to
partially provide a variety of forest resource uses,
including habitat for threatened and endangered
species and other wildlife, as well as watershed,
recreation, scenic and other values.
In accordance with the National Environmental
Policy Act, this EIS identifies impacts on the
natural and human environment associated with
nine alternatives. The EIS is based primarily on
data collected and analyzed through the Bureau
planning system which included extensive public
involvement. Alternative 9, developed to meet new
policy for O&C lands, is the Preferred Alternative.
Eight other alternatives have been identified,
providing a wide range of options for review and
consideration. A basic assumption incorporated
into the analysis is that sufficient funding and
personnel will be available for implementation of
any alternative.
Alternatives
Timber harvest under all alternatives would
be accomplished predominately by clearcutting,
with some single tree selection. Intensive timber
management treatments would include
construction of logging roads, site preparation
with burning, mechanical means and herbicide
application, planting coniferous trees (including
genetically improved stock), plantation protection,
plantation maintenance and release with
herbicides or manual means, precommercial
thinning and fertilization. Alternative 7 excludes
the use of herbicides and fertilization.
Variables among alternatives include amounts of
land allocated to timber production, types and
amounts of intensive management practices,
harvest scheduling and constraints on timber
harvest to benefit other resource values. The
minimum size of timber available for final harvest
also varies by alternative. Harvest at the minimum
size, reached in 40 to 50 years for all alternatives
except 8, would begin in approximately the fifth
decade. Harvest at the minimum size would
continue for 6 to 23 decades, depending on the
alternative. The proposed alternatives are:
1. Maximum Timber Production. This alternative
maximizes timber production while meeting legal
requirements to protect federally listed threatened
and endangered species and cultural resources. It
would allocate 386,622 acres of commercial forest
land to intensive timber management and produce
an annual timber sale program of 289 MM bd. ft.
Operational and spatial constraints on timber
harvest and stand regeneration would be
minimized. The average minimum size of trees in
stands available for final harvest would be 12.7
inches diameter breast height (dbh), normally
reached in 40 years.
2. Emphasis on Timber Production. This
alternative would allocate 360,580 acres of
commercial forest land to intensive timber
management with an additional 24,786 acres
managed under modified area control. This would
produce an average timber sale program of 267
MM bd. ft. annually. A longer harvest cycle
(average of 250 years) under modified area control
would provide timber harvest while protecting
some resources in riparian areas, wildlife habitat
and visual corridors. The average minimum
diameter of trees in stands available for final
harvest would be 14.4 inches dbh, normally
reached in 50 years.
3. Lower Average Minimum Harvest Size. This
alternative allocates 333,319 acres of commercial
forest land to intensive timber management with
an additional 52,047 acres managed under
modified area control. Under the intensive timber
production base, the average minimum diameter of
trees in stands proposed for final harvest would be
12.7 inches dbh, normally reached in 40 years.
This alternative would produce an average timber
sale program of 256 MM bd. ft. annually.
4. Original Proposed Action. This alternative is
identical to Alternative 3 except that minimum
harvest size is increased, shortening the time to
achieve a regulated forest. The minimum average
tree diameter in stands selected for final harvest
would be 14.4 inches dbh compared to 12.7 inches
dbh under Alternative 3. The minimum harvest age
would be 50 years, providing an average annual
timber sale program of 249 MM bd. ft.
5. No Action (No Change). A required alternative
in the EIS, this would constitute a continuation of
the present annual timber sale program of 201 MM
bd. ft. on 390,984 acres. It would continue the
intensive management practices and constraints
identified in the 1972 allowable cut determination.
Non-timber allocations, limited to 400 acres,
include buffers for recreation areas and sensitive
visual corridors. Streamside buffers totaling 8,070
acres would be provided along third order and
larger streams.
6. Habitat Diversity. This alternative emphasizes
protection of natural and cultural values, while
accommodating production of timber. It would
allocate 222,357 acres to intensive forest
management with an additional 119,924 acres
managed under longer harvest cycles. The annual
timber sale program would be 183 MM bd. ft. The
minimum average diameter of trees in the intensive
timber management stands available for final
harvest would be 14.4 inches dbh, normally
reached in 50 years.
7. No Herbicides, Fertilizer or Allowable Cut Effect
for Genetics. This alternative is similar to
Alternative 4 in timber base and treatments, except
that herbicides and fertilizer would not be used. It
would provide for continued planting of
genetically improved trees, but the allowable cut
computation would not take credit for expected
growth increases. The average timber sale
program would be 176 MM bd. ft. annually. The
minimum average diameter of trees in stands
available for final harvest would be 13.6 inches
dbh, normally reached in 50 years. Vegetation
management practices in lieu of herbicides would
be prescribed to approximately the same dollar
level of investment as would be used for fertilizer
and herbicide applications.
8. Emphasis on Protection of Natural Values.
Under this alternative, protection is provided for a
variety of wildlife habitats, sensitive botanical
species, cultural resources, visual resources,
research natural areas, riparian areas and
dispersed recreational activities. Approximately
262,436 acres of commercial forest land would be
included in the constrained timber base. Minimum
harvest ages would vary from 60 to 350 years. This
would produce an annual timber sale program of
84 MM bd. ft. Fifteen-year spacing between harvest
areas would be employed. Timber harvest would
be allowed only when direct benefit to the
protected resources would result. This is
considered to be a full ecosystem alternative.
9. New Preferred Alternative. This alternative is a
modification of the Original Proposed Action
(Alternative 4) resulting from application of the
new O&C Forest Resources Policy. The alternative
seeks a high level of timber production (247 MM
bd. ft. /year) while managing for a variety of natural
values and recreation opportunities. This
alternative would allocate 331,637 acres of
commercial forest land to intensive management
with an additional 35,868 acres managed under
modified area control. An estimated 23,565 acres
of commercial forest land would be withdrawn to
protect riparian areas, bald eagles, Research
Natural Areas, botanical species and cultural
resources.
Environmental
Consequences
Air Quality
The major impact on air quality would be
from slash burning. Particulate emissions range
from 1,142 tons to 3,828 tons per year.
Soils
Impacts to soils are mainly due to road
construction, landslides and compaction.
Alternative 1 has the greatest long-and short-term
impacts while Alternative 8 has the least.
Production losses range from 2,647 equivalent
acres under Alternative 8 to 9,136 equivalent acres
under Alternative 1. Less significant impacts
include nutrient losses, dry ravelling and topsoil
removal.
Water Resources
Sediment yield would increase under
Alternatives 1 to 3, decrease under Alternatives 4,
6, 7, 8 and 9. Water yield increases are expected
under Alternatives 1 to 5 and 9, decreases under
Alternatives 6, 7 and 8. Water temperature would
increase under Alternative 1. Based on the sample
5-year sale plan, timber harvest activities planned
in four municipal watersheds would increase water
yield and sedimentation.
Vegetation
Alterations to plant community structure and
longevity would be the most significant impacts to
vegetation on lands scheduled for timber harvest.
Acres scheduled for timber harvest over the next
decade would range from 74,807 under Alternative
1 to 19,915 under Alternative 8. Mature and old-
growth forest communities would be converted to
early successional stage communities as slow-
growing timber stands are replaced by young, fast-
growing stands. Diversity and complexity of plant
communities would diminish as maximum growth
of commercial conifers is emphasized. Changes in
plant communities and habitat could eliminate
some plant species in the long term. Plant habitat
altered by herbicides would increase under all
alternatives except 7 and 8. Permanent road
construction during the decade would eliminate
vegetation from public land, ranging from 5,568
acres under Alternative 1 to 1,662 acres under
Alternative 8.
Animals
Habitat diversity would increase in the
short term. However, in all alternatives except 8,
there would be significant long-term adverse
impacts to some animal populations due to a
decrease in habitat diversity and, in particular, a
reduction in the mature and old growth
components of the forest. Simplification of
habitats due to intensive forest management
practices would add to this impact.
Riparian habitat would be adequately protected by
Alternatives 6, 8 or 9, but would be adversely
impacted by all other alternatives. Increases in
sediment yield in Alternatives 1 through 3 and
increases in water temperature in Alternative 1
would negatively impact fish. Fish would increase
in Alternatives 4, 6, 7, 8 and 9.
Snag-dependent wildlife would be greatly reduced
in the long term, but impacts would be minimal in
the short term. In the long term, elk numbers are
expected to decline in all alternatives except 8. Elk
numbers would increase in the short term in all
alternatives.
There would be no known adverse impacts to any
species listed by the Federal Government as
threatened or endangered. The northern spotted
owl, listed by the State of Oregon as threatened,
may be adversely impacted in the long term by all
alternatives except 8.
Recreation
The impacts of timber management operations
would be both beneficial and adverse, depending
on the recreational experience desired. Visitor use
increases or reductions may occur in certain areas
as a result of impacts to specific recreational
experiences.
Impacts would depend upon the approach taken to
meet recreational needs. For the long term,
Alternative 5 would fall short of meeting demand in
many activities with identified area and facility
needs. Alternative 1 emphasizes those activities
having minimal impact on the commercial timber
base and would not provide for new developed
sites. Alternatives 2, 3, 4, 7, and 9 provide a variety
of opportunities to meet most needs. Alternatives 6
and 8 emphasize dispersed activities, natural areas
and the opportunity for site development, although
Alternative 8 would not meet the need for off-road
vehicle areas and trails. In the long term, area-wide
elk hunting opportunities are expected to be
adversely impacted under all alternatives except 6
and 8, while fishing opportunities are expected to
be adversely impacted under Alternatives 1
through 3.
Cultural Resources
Appropriate measures would be taken to
identify and protect cultural sites prior to ground-
disturbing activities under all alternatives.
Undiscovered cultural sites would be susceptible
to considerable alteration and damage. Once a site
is found, however, mitigation measures will be
instituted to minimize or avoid damage. Under all
alternatives, significant sites identified before,
during and after logging would be managed to
protect scientific and/or interpretive values.
Visual Resources
Under Alternative 8, visual resource
conditions (scenic quality) would improve. Under
Alternative 6, most highly scenic and/or sensitive
areas would be protected with slight adverse
impacts in some areas of the SYUs. Adverse visual
impacts under Alternatives 2, 3, 4, 7, and 9 would
be low to moderate. Many highly scenic and/or
sensitive areas would be protected.
Under Alternatives 1 and 5, adverse visual impacts
would be high with some protection provided for
certain highly scenic and/or sensitive areas,
primarily essential bald eagle habitat and existing
recreation sites.
Areas of Critical Environmental
Concern
Area of Critical Environmental Concern
(ACEC) designation would provide guidelines to
help achieve resource protection in those areas
designated. All alternatives except 5 provide some
level of ACEC designation greater than the
existing situation. Designation ranges from four
areas (600 acres) under Alternative 1 to seven
areas (3,100 acres) under Alternatives 6 and 8.
Special Areas
Alternative 1 allows for designation of
those areas which would not affect the commercial
timber production base of the SYUs. Alternatives
2, 3, 4, 7, and 9 allow for designation of those
areas identified as having significant natural values
for science, recreation or education. Alternative 5
provides no additional natural area designation
above that under the existing situation.
Alternatives 6 and 8 emphasize the study and
designation of natural areas. However, some sites
(e.g., Red Pond, Dompier Creek Landslide) with
natural and environmental education values may
be adversely impacted if they are not designated
or otherwise protected.
Human Health
The possibility of human health being
impacted by the use of herbicides is related to the
toxicity of the herbicide, the likelihood of
exposure, and resulting dosage received. Based on
current knowledge and the low risk of exposure on
BLM-treated acres, an unreasonable risk to human
health from continued, careful use of herbicides is
unlikely. Herbicides would not be used under
Alternative 7.
Energy Use
Fossil fuel energy would be consumed in all
phases of the 10-year timber management plan.
The annual energy consumption ranges from 218
billion Btu's (Alternative 8) to 834 billion Btu's
(Alternative 1). The annual energy consumption
attributable to the New Preferred Alternative
(Alternative 9) would be approximately 716 billion
Btu's.
Socioeconomics
Compared to timber harvest levels in Douglas
County from 1976-1980, Alternatives 1 through 5
and 9 would increase employment in the timber
industry and total local employment and earnings.
The New Preferred Alternative (Alternative 9)
could result in an increase of 440 timber industry
jobs and 1,023 jobs in total. The greatest increase
in jobs would be the result of Alternative 1 ,
yielding 751 timber industry jobs and 1,746 total
jobs. Alternative 8 would result in a net loss of 766
timber industry jobs and 1,780 total jobs.
Compared with continuation of the current timber
management program, Alternatives 1 through 4
and 9 add economic activity. In this comparison,
the New Preferred Alternative (Alternative 9) would
add 340 timber industry jobs and 791 jobs in total.
At the extremes, Alternative 1 could stimulate up
to 1,514 new jobs while Alternative 8 could impact
the regional economy by a reduction of 2,012 jobs.
Public revenues would be increased or maintained
for Alternatives 1 through 5 and 9 and decline for
Alternatives 6 through 8.
Table of Contents
Page
Summary 3
Chapter 1 Description of Alternatives Including the Proposed Action 11
Purpose of and Need for the Action 11
Alternatives 12
Alternative 1 - Maximum Timber Production 13
Alternative 2 - Strong Emphasis on Timber Production 13
Alternative 3 - Lower Average Minimum Harvest Size 13
Alternative 4 - The Original Proposed Action 15
Alternative 5 - No Action 15
Alternative 6 - Habitat Diversity 15
Alternative 7 - No Herbicides, Fertilizer or Allowable Cut Effect for Genetics 15
Alternative 8 - Emphasis on Protection of Natural Values 15
Alternative 9 - New Preferred Alternative 16
Forest Management Treatments and Design Elements 16
Transportation System 17
Timber Harvest 17
Site Preparation 17
Planting 19
Plantation Protection 19
Plantation Maintenance and Release 19
Precommercial Thinning 20
Fertilization 20
Comparison of Impacts 20
Implementation 20
Final Decision 20
Monitoring and Studies 20
Requirements for Further Environmental Assessment 22
Interrelationships 22
Federal Agencies 22
State and Local Governments 23
8
Page
Chapter 2 Affected Environment 27
Climate and Air Quality 28
Geology and Topography 29
Soils 29
Water Resources 30
Vegetation 35
Terrestrial Vegetation 35
Wetland and Aquatic Vegetation 38
Sensitive, Threatened and Endangered Plants 38
Animals 39
Terrestrial Animals 39
Fish 41
Threatened and Endangered Animals 42
Recreation 43
Cultural Resources 43
Prehistoric Sites 44
Historic Sites 44
Paleontologic Sites 44
Visual Resources 45
Wilderness Values 45
Areas of Critical Environmental Concern 45
Special Areas 45
Socioeconomic Conditions 46
Timber Industry 53
Fishing, Hunting and Other Recreation 53
Social Concerns 53
Chapter 3 Environmental Consequences 59
Introduction 59
Impacts on Air Quality 60
Conclusions 61
Impacts on Soils 61
Conclusions 63
Impacts on Water Resources 63
Water Quantity 63
Water Quality 63
Municipal Watersheds 65
Conclusions 65
Impacts on Vegetation 65
Terrestrial Vegetation 66
Threatened or Endangered Plants 67
Conclusions 68
Impacts on Animals 68
Terrestrial Vertebrates 68
Fish 74
Threatened and Endangered Animals 75
Conclusions 76
Impacts on Recreation 77
Conclusions 78
Impacts on Cultural Resources 78
Conclusions 79
Impacts on Visual Resources 79
Impacts on Areas of Critical Environmental Concern 81
Impacts on Special Areas 81
Impacts on Energy Use 81
Impacts to Human Health 82
Impacts on Socioeconomic Conditions 84
Chapter 4 Consultation and Coordination of the Draft
Environmental Impact Statement 89
Statement 89
List of Agencies, Organizations and Persons to Whom Copies of the Statement are Sent 149
List of Preparers 1 50
Appendices 153
9
Page
Glossary 1 89
References Cited 197
Index 205
Tables
1-1 Land Jurisdiction in Acres by County within Roseburg Sustained Yield Units 13
1-2 Comparison of Proposed Action and Alternatives by Treatment — First Decade 14
1-3 Derivations of Timber Production Base Acreage 14
1-4 Estimated Ten-Year Use of Herbicides 18
1-5 Summary of Impacts 21
1-6 Relationship of Roseburg EIS Alternatives to LCDC Statewide Goals 24
1-7 Consistency of the Roseburg Alternatives with the Basic Objectives of the Forestry Program
for Oregon 25
1-8 Consistency of the Alternative with State of Oregon Wildlife Goals 26
2-1 Total Suspended Particulates in Roseburg 28
2-2 Slash Smoke Problems in Douglas County 29
2-3 Bared Soils and Rose Surfaces 30
2-4 Fragile and Problem Soils 30
2-5 Severe Water Quality Problems 35
2-6 Streamf low Data 36
2-7 Sediment Discharge Data 37
2-8 Existing Forest Habitat Stratification of Entire Roseburg Area 38
2-9 Sensitive Species Currently under Review for Possible Listing 39
2-10 Habitat Structure of Forest Lands in the SYUs 40
2-1 1 Salmonoid Fish and Habitat Populations 42
2-12 Threatened and Endangered Species of the SYUs 42
2-13 Estimated Current and Projected Visitation Attributed to Major Recreation Activities 44
2-14 Nominated and Potential Areas of Critical Environmental Concern 46
2-15 Population, 1960-1980 49
2-16 Components of Population Change, 1970-1980 49
2-17 Average Size and Recent Growth of the Labor Force and Employment in Industries 50
2-18 Total and Rate of Growth of Labor and Proprietors' Income in Selected Industries
Affected by Timber Management in the Roseburg District 50
2-19 County Revenue Sources as a Percentage of Total Revenues and County Revenues
Per Capita for Fiscal Years 1977-1978 51
2-20 O&C Revenue Distribution to Counties Expressed as Property Tax Rate Equivalent
and as a Percent Supplement to Total Levy, Fiscal Years 1977-1980 52
2-21 In-Lieu Tax Payment on CBWR Lands Administered by BLM in Douglas County 52
2-22 Timber Harvest by Ownership Class, Douglas County 53
2-23 Dependency of Log Processors in Oregon and Douglas County on BLM Timber 54
2-24 Harvest Sales and Receipts, BLM Timber in the Roseburg District 54
2-25 Average Annual Local Economic Effects of Timber Management on Lands
Administered by the Roseburg District 55
2-26 Local Economic Effects of Fisheries, Terrestrial Wildlife and General Recreation 56
2-27 Changes Desired by Survey Respondents in the Use of Federal Lands 57
3-1 Average Emission Components from Slash Burning 61
3-2 Estimated Loss of Productivity During First Decade 62
3-3 Expected Nutrient Losses from Timber Harvesting and Slash Burning 62
3-4 Estimated Annual Water Yield from BLM-Administered Land, End of First Decade 63
3-5 Estimated Sediment Through Buffer Strips 64
3-6 Estimated Sediment Yield from BLM-Administered Land, End of Decade 65
3-7 Proposed Activities in Municipal Watersheds Based on the Sample Five Year
Timber Sale Plan 65
3-8 Approximate Acres of BLM-Administered Timber Lands and Percent of Change
after One Decade 66
3-9 Acres of Old Growth and Percent Change from Existing on BLM-Administered Lands
Remaining at the End of Each Decade 69
3-10 Estimated Elk Population Changes on BLM-Administered Lands in the Tyee Area 71
3-1 1 Long-Term Snag Density 72
3-12 VRM Classes 80
3-13 Potential Impacts of the Sample Five-Year Timber Sale Plan on Visual Resources 80
3-14 Potential Impacts to Areas Qualified for ACEC Designation 82
10
Page
3-15 Potential Impacts to Special Areas 82
3-16 Estimated Annual Energy Consumption 83
3-17 Herbicide Toxicity 83
3-18 Short-Term Impacts Compared to No Action Condition on Local Employment and
Earnings Related to Timber Harvest 85
3-19 Projected Distribution of O&C Payments from SYUs to Counties by Alternative 86
3-20 Projected Distribution of Severance Taxes on CBWR Lands by Alternative 86
Figures
Vicinity Map 7
1-1 Roseburg SYU-EIS Area Inside Back Pocket
2-1 Physiographic Province 31
2-2 General Soils 33
2-3 Visual Resource Management 47
2-4 Annual Average Lumber and Wood Products Employment; Douglas County, Oregon 1970-1980 56
A-1 Western Oregon Tree Seed Zones 157
C-1 Allowable Cut Effect 171
C-2 Allowable Cut Determination Process 172
11
Chapter 1 Description of
Alternatives Including the
Proposed Action
Purpose of and Need for the
Action
The Bureau of Land Management (BLM) proposes
to implement, beginning October 1, 1983, an
updated 10-year timber management plan for the
and South Umpqua Sustained Yield Units in the
Roseburg Douglas District, Oregon (Figure 1-1,
folded map in the back cover pocket). The
Douglas and South Umpqua Sustained Yield Units
will be referred to in this document as Roseburg
Sustained Yield Units (SYUs). These are primarily
revested Oregon and California Railroad (O&C)
and reconveyed Coos Bay Wagon Road (CBWR)
grant lands. There are also scattered remnants of
the original Public Domain (PD) lands. In
accordance with the National Environmental
Policy Act (NEPA), this EIS identifies impacts on
the natural and human environment associated
with nine alternatives. The 10-year timber
management plan for the two SYUs provides
direction for management of these lands as
required by the acts mentioned below.
The Bureau's principal authority and direction to
manage the O&C and CBWR grant lands is found
in the O&C Act of 1937 (50 Stat. 874; 43 U.S.C.
1181a., et seq.). The disposition of funds derived
from the CBWR grant lands is described in an act
approved on May 24, 1939 (43 U.S.C. 1181f-l et
seq.). Under these acts, O&C and CBWR lands
12
classified as timberlands are to be managed under
sustained yield principles in order to provide a
permanent source of timber supply, watershed
protection, stream flow regulation and recreational
facilities. Intermingled PD lands were brought
under sustained yield management principles by
the Bureau's 1962 application to withdraw these
lands from entry under all public land laws except
certain disposal acts. Withdrawal was completed
by Public Land Order 5490 in 1975 (40 FR 7450). In
addition, many activities of the BLM are governed
by the Federal Land Policy and Management Act
of 1976 (90 Stat. 2743, 43 U.S.C. 1701). This law,
often referred to as FLPMA, established policy for
BLM administration of public lands under its
jurisdiction.
Notwithstanding any provision of FLPMA, in the
event of conflict with or inconsistency between
FLPMA and the O&C Act of August 28, 1937 (50
Stat. 874; 43 U.S.C. 1181a-1181j), and the Act of
May 24, 1939 (43 USC 1181M et seq.), insofar as
they relate to management of timber resources
and disposition of revenues from lands and
resources, the 1937 and 1939 acts shall prevail.
The O&C Forest Resources Policy to be used in
formulating decisions for BLM-administered forest
lands in western Oregon was approved by the
Director in March 1983. A copy of the policy is
included in this EIS in Appendix A. To respond to
the policy, an additional alternative has been
included in this FEIS and is designated BLM's New
Preferred Alternative (Alternative 9).
During an EIS scoping meeting held in Roseburg,
Oregon (October 19, 1981), participants were
asked to identify issues and alternatives to be
addressed in this EIS. Chapter 1 includes
alternatives identified during scoping and
considered appropriate for full analysis.
Alternatives identified but not considered
appropriate for full analysis, and the rationale for
these determinations are presented in Appendix B,
which summarizes the scoping meeting. A
discussion of the economic efficiency of the
timber management program for the Original
Proposed Action and Alternative 9 (New Preferred
Alternative) is included in Appendix B.
During the planning process, criteria (Appendix C)
were used to evaluate alternatives and select a
proposed land use allocation alternative. The
results of this evaluation, combined with public
input, led to the original proposed land use
alternative, Alternative 4 in this EIS.
Appendix C also addresses inventory methods
used to arrive at the timber production base,
allowable cut determination and other land use
allocations. Acreages for land use allocations by
alternative are shown in Appendix C, Table C-2.
The alternatives prepared for the SYUs identify
various timber harvest levels, management
practices and mitigating measures to protect the
land and other resources. This information is
described in detail in the remainder of this
document.
Alternatives
Planning for the Roseburg Sustained Yield
Units (SYUs) focused on the 423,896 acres of
public land administered by BLM. Except for 280
acres in Lane County and 400 acres in Jackson
County, all lands are in Douglas County. BLM
administers 29 percent of the total land within the
Roseburg SYUs (Table 1-1).
There are nine alternatives, including the
Original Proposed Action (Alternative 4) and the
New Preferred Alternative (Alternative 9), for
which impacts will be analyzed in Chapter 3:
1. Maximum Timber Production (Max. Tbr.)
2. Emphasis on Timber Production (Emp. Tbr.)
3. Lower Average Minimum Harvest Size (Lo MHS)
4. Original Proposed Action (OPA)
5. No Action
6. Habitat Diversity (HD)
7. No Herbicides, Fertilizer or Allowable Cut Effect
for Genetics (No Herb.)
8. Emphasis on Protection of Natural Values (Full
Eco.)
9. New Preferred Alternative (NPA)
For each alternative, a sustained yield harvest level
(allowable cut) has been calculated based on the
combined timber production base (see Glossary)
of the two SYUs. All allowable cut computations
are made in cubic feet and converted to Scribner
board feet equivalence for the first decade. There
is no surplus inventory (see Glossary). Variables
between alternatives include amounts of land
allocated to timber production, types and amounts
of intensive management practices and constraints
on timber harvest to benefit other resource values.
These relationships are displayed in Table 1-2.
Treatments and design elements applicable to
each alternative are discussed in the Forest
Management Treatments and Design Elements
section of this chapter.
All harvest levels shown in Table 1-2 are computed
on the respective combinations of intensive and
constrained timber production bases. Table 1-3
displays the breakdown by category and
alternative. On areas allocated to constrained
timber production (see Glossary), minimum
harvest ages (MHA) vary to recognize specific
needs for wildlife habitat diversity and visual
resource management (VRM) considerations. The
timber production base, for all alternatives except
Alternative 5, excludes fragile site and
reforestation problem withdrawals (approximately
1 1 ,000 acres) and a minimum of 4,448 acres of
commercial forest land withdrawn to protect
Table 1-1 Land Jurisdiction in Acres 1 by County within Roseburg
Sustained Yield Units
13
BLM 2
U.S. Forest
Service
State
Local Govt.
& Private
Total
280
280
400
400
423,216
978
3,948
1,032,150
1,460,292
423,896 3
978
3,948
1,032,150
1,460,972
County
Lane
Jackson
Douglas
Totals
' Acreage figures for BLM-administered lands are derived from master title plats. Other acreage figures are from Resource Atlases
published by O.S.U. Extension Service, 1964.
2 O&C lands make up 93 percent of the public lands administered by BLM. PD and CBWR lands comprise the remaining 4 and 3 percent,
respectively.
3 Refer to Appendix C, Table C-2.
certain natural and cultural resources. Appendix C
explains these withdrawals in more detail
(Appendix C, Table C-2).
Alternatives 2, 3, 4, 7 and 9 include modified area
control (see Appendix C), which is a process for
managing a given number of acres under a special
timber harvest regime. In the Roseburg SYUs,
52,047 acres are planned to be managed under the
modified area control concept for Alternatives 3, 4
and 7, 35,868 acres for Alternative 9 and 24,786
acres for Alternative 2. These acres are primarily
managed for riparian, spotted owl, old growth and
visual values and are generally located within a
corridor. This process would yield a timber harvest
of approximately 4 MM bd. ft. in Alternative 2, 6
MM bd. ft. in Alternative 9 and 9 MM bd. ft. in
Alternatives 3, 4 and 7. Harvest methods would
vary, ranging from clearcut to individual tree
selection.
Alternative 1 - Maximum
Timber Production
Timber production would be maximized while
meeting legal requirements to protect federally
listed threatened and endangered species and
cultural resources. This alternative would allocate
386,622 acres to intensive timber management and
provide an annual timber sale program of 289 MM
bd. ft. through accomplishment of various
intensive timber management practices (see Table
1-2). Lands not allocated to timber production
(4,448 acres) would be managed for other
resources such as cultural, established recreation
sites and threatened and endangered species.
Timber available for final harvest would have an
average size of 12.7 inches dbh, normally reached
in 40 years. Harvest at this size would occur during
the 5th through 17th decades of the 400-year
projection period.
This alternative provides for harvest of stream
buffers consistent with the Oregon Forest
Practices Act; however, specific protection for
riparian zones, wetlands and northern spotted
owls would not be provided.
Alternative 2 - Strong Emphasis
on Timber Production
Under this alternative, 360,580 acres of
commercial forest land would be allocated to
intensive timber management with an additional
24,786 acres managed under modified area control
(Appendix C). This would provide an annual
timber sale program of 267 MM bd. ft. Stream
buffers averaging 200 feet wide would be provided
on third order or greater streams managed under
modified area control. Approximately 5,700 acres
of commercial forest land would be withdrawn
from the allowable cut base to provide for other
resource uses (Appendix C, Table C-2). Timber
available for final harvest in the intensive timber
base would have an average size of 14.4 inches
dbh, normally reached in 50 years. Harvest at this
size would occur from the 5th through 10th
decades during the 400-year projection period.
Alternative 3 - Lower Average
Minimum Harvest Size
Allocation of 333,319 acres of commercial
forest land to intensive timber management would
occur under this alternative. An additional 52,047
acres, including an average 200-foot buffer on
third order and greater streams and selected VRM
lands and wildlife habitat, would be managed
under modified area control (Table 1-3 and
Appendix C, Table C-4). This would produce an
average timber sale program of 256 MM bd. ft.
annually. Approximately 5,700 acres of
commercial forest land would be withdrawn from
the allowable cut base to provide for other
resource uses.
14
Table 1-2 Comparison
of Alternatives by Treatment - First Decade
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Alt. 6
Alt. 7
Alt 8
Alt. 9
Max.
Emp
Lo
No
No
Full
Tbr.
Tbr.
MHS
OPA
Action
HD
Herb.
Eco.
NPA
Intensive Timber
Production Base' (acres)
386.622
360.580
333.319
333.319
377.098
222.357
261 191
331.637
Constrained Timber
Production Base' (acres)
24.786
52.047
52.047
13.886
119.924
52.047
262,436
35.868
Annual Harvest
Total Million bd ft
289
267
256
249
201
183
176
84
247
Total Million cu It
47 46
4381
4203
41 00
3303
30 28
28 94
1383
40 47
Treatments 2
Transportation System (miles. acres)
New Construction '
928:5.568
854,5.124
822:4,932
800;4,800
616:3.696
588.3,528
551:3,306
277, 1,662
794.4.764
Reconstruction
641;
590;
568.
552:
425:
406.
381;
191:
548;
Timber Harvest (acres)
Clearcut
66.780
61,411
59.152
57.548
44.294
42.298
39,659
19.915
57.093
Mortality Salvage
4.138
3,830
3,325
3,347
21.949
2.362
2.646
3.328
Commercial Thinning
3,889
3.611
3.479
3.479
7,357
2.778
2.802
1.383
Site Preparation (acres)
Broadcast Burning
(slash disposal)
52,088
47.901
46.139
44,887
34.549
32.992
30,659
15.534
44.532
Herbicide
60.770
55.884
53,828
52,369
40,308
38.491
18.123
51 955
Manual
2.003
1,842
1.775
1.726
1,329
1.269
23,790
597
1.713
Mechanical
4.675
4.299
4.141
4.028
3.101
2,961
2,776
1.394
3,997
Planting (acres)
Initial plant'
61,212
56,287
54.220
52.748
40,598
38.770
36.353
18.253
52.329
Replant or Interplant
18,364
16.886
16.266
15,824
12.179
11.631
10.906
5.476
15,698
Plantation Protection (acres)
36,061
33,162
31.942
31,076
23.919
22.841
21,416
10.754
30.830
Plantation Maintenance and
46,746
42,988
41.406
40,284
31.006
29.609
7,300
13,940
39.965
Release- (acres)
Precommercial Thinning (acres)
44.576
42,240
40.755
40,755
12.326
31.370
37.319
40,449
Fertilization (acres)
61.270
57.984
56,029
56,029
43.659
55,646
1 See Glossary.
2 Each treatment is described in detail following description of the alternatives.
1 Figured at the rate of 6 acres/mile of road includi
ing landings.
J Under all alternatives except Alternati
ve 8, 15,200 acres would be planted
with genet
ically improved stock.
5 All to be accomplished
with herbicides except in
Alternative 7
where manual methods are to be
employed
exclusively.
Table 1-3 Derivations of Timber Production Base Acreage
Alternatives Including the Proposed Action
Alt. 1
Max.
Tbr.
Alt. 2
Emp.
Tbr.
All. 3
Lo
MHS
Alt. 4
OPA
Alt. 5
No
Action
Alt. 6
HD
Alt. 7
No
Herb.
Alt. 8
Full
Eco.
Alt. 9
NPA
INTENSIVE TIMBER
PRODUCTION BASE
386,622
360,580
333.319
333,319
377,098
222.357
261,191
331.637
CONSTRAINED TIMBER
PRODUCTION BASE
VRM (250 year modified
area control)
VRM (MHA-130)
Wildlife (250 year
modified area control)
Wildlife (MHA-60)
Wildlife (MHA-250)
Wildlife (MHA-350)
3.682
21,104
2,646
49,401
2,646
49,401
31.345
76,359
12,220
2,646
49,401
49.376
107.180
83.211
22.669
2.658
33,210
TOTAL CONSTRAINED
24.786
52.047
52.047
13.886
119,924
52.047
262.436
35.868
TOTAL TIMBER
PRODUCTION BASE'
386.622
385.366
385.366
385,366
390,984
342.281
313,238
262.436
367.505
' Refer to Land Use Allocati
on. Append
ix C, Table C-2
15
Timber stands available for final harvest in the
intensive timber base would have an average size
of 12.7 inches dbh, normally reached in 40 years.
In actuality, harvest at this size would occur from
the 5th through the 28th decades during the 400-
year projection period. A regulated forest on
intensive timber production lands would be
reached in about the 30th decade. It is assumed
that by the time a regulated forest is achieved, the
annual harvest level from the lands allocated to
timber production under this alternative and the
Original Proposed Action (Alternative 4) could be
increased to the highest level sustainable from this
timber management base (estimated to be
approximately 303 MM bd. ft.).
Alternative 4 - The Original
Proposed Action
This alternative allocates the same acreages
to timber and other resource management as
Alternative 3. However, timber available for final
harvest in the intensive timber base would have an
average size of 14.4 inches dbh, normally reached
in 50 years. This would produce an average annual
timber sale program of 249 MM bd. ft. Harvest at
this size would occur from the 4th through the
10th decades during the 400-year projection
period. A regulated forest on intensive timber
production lands would be reached in about 13
decades. Management elements would be identical
to those in Alternative 3 (see Tables 1-2, 1-3 and
Appendix C, Tables C-3, C-4).
Alternative 5 - No Action
Alternative 5 constitutes a continuation of
the present allowable cut of 201 MM bd. ft. from
390,984 acres allocated to timber production.
Continuation of the same management practices,
level of application and constraints used in the
1972 allowable cut calculation is assumed.
Management trends (such as reduced tractor
yarding) established over the past decade would
be continued. Minimal protection would be
provided for some highly scenic areas,
recreational sites and wildlife habitat. Non-timber
allocations, limited to 400 acres, include buffers
for recreation areas and sensitive visual corridors.
Streamside buffers totaling 8,070 acres would be
provided along third order and larger streams
(Table C-4). Other land use allocations (Appendix
C, Table C-2) and management objectives (Table
1-2) proposed under this alternative are those
incorporated in the 1972 Timber Management Plan
for its second decade of application.
Alternative 6 - Habitat Diversity
Protection of some natural and cultural
values, while accommodating timber production
and other commodities, would be provided under
Alternative 6. It would allocate 222,357 acres to
intensive forest management with an additional
119,924 acres managed under longer harvest
cycles. The annual timber sale program would be
183 MM bd. ft. Timber available for final harvest in
the intensive timber base would have an average
size of 14.4 inches dbh, normally reached in 50
years. Stream buffers at least 250 feet wide would
be provided on third order and greater streams. In
addition, 48,790 acres of commercial forest land
would be withdrawn from the allowable cut base to
provide for other resource uses (Appendix C,
Table C-2).
Alternative 7 - No Herbicides,
Fertilizer or Allowable Cut
Effect for Genetics
This alternative differs from Alternative 4
in that the forest management treatments of
herbicide and fertilizer applications would not be
incorporated. Without the use of herbicides to
control competing vegetation, approximately
72,100 acres would be withdrawn from the timber
production base due to reforestation problems.
Control of vegetation for timber management by
using biological, mechanical or manual means
would be prescribed to approximately the same
dollar level of investment as would be used for
herbicide and fertilizer applications in Alternative 4
to provide a means of comparison.
Alternative 7 would provide for continued planting
of genetically improved trees, but the allowable cut
computation would not take credit for expected
growth increases. This would produce an average
annual timber sale program of 176 MM bd. ft.
Timber available for final harvest in the intensive
timber management base would have an average
size of 13.6 inches dbh, normally reached in 50
years.
Alternative 8 - Emphasis on
Protection of Natural Values
In this alternative, protection would be
provided for a variety of wildlife habitats, sensitive
botanical species, visual resources, research
natural areas, riparian areas and dispersed
recreational activity areas. Unharvested stream
buffers, varying in width by stream order from 150
to 500 feet, would be provided on all streams. This
is considered to be a full ecosystem alternative.
No land would be included in the intensive timber
base. Treatments not planned for Alternative 8 are
mortality salvage, commercial and precommercial
thinning, fertilization and genetically improved
stock (Table 1-2). Approximately 262,436 acres of
commercial forest land would be included in the
constrained timber base (Table 1-3). Minimum
harvest age varies from 60 years to 350 years. This
would produce an average timber sale program of
84 MM bd. ft. annually. Fifteen-year spacing
between adjacent harvest areas would be
employed. In addition, 128,634 acres of
16
commercial forest land would be withdrawn from
the allowable cut base to protect non-timber
resource values (Appendix C, Table C-2). Harvest
from these areas would be allowed only when of
direct benefit to the protected resources.
Alternative 9 - New Preferred
Alternative
This alternative seeks a high level of
timber production while managing for a variety of
natural values and recreation opportunities. This
alternative is similar to Alternative 4, except that
18,332 acres of riparian area along third order and
greater streams would be withdrawn from the
allowable cut base.
Under this alternative 331,637 acres of commercial
forest land would be allocated to intensive timber
management with an additional 35,868 acres
managed under modified area control. This would
produce an average annual timber sale program of
247 MM bd. ft. Timber available for final harvest in
the intensive base would have an average size of
14.4 inches dbh, normally reached in 50 years.
Harvest at this size would occur from the 4th
through the 10th decades during the 400-year
projection period. A regulated forest on intensive
timber production lands would be reached in
about 13 decades. An additional 5,233 acres of
commercial forest land would be withdrawn from
the allowable cut base to provide for cultural and
botanical resources, bald eagles and recreation
sites (Table C-2).
Forest Management
Treatments and Design
Elements
Table 1-2 displays, in typical sequence, the types
and levels of treatments for each alternative.
Following harvest by clearcut or single tree
selection, these treatments are used to achieve
prompt reforestation and to increase subsequent
growth of commercial coniferous species. The
following discussion of treatments will be in the
same order as listed in Table 1-2.
Not every treatment listed in Table 1-2 would be
applied to every acre. A number of treatment
combinations are possible and could be employed.
The purpose of this section is to elaborate on what
each treatment entails and quantify the magnitude
of the actions. Treatments would be identified and
scheduled through application of the recently
adopted forest data system (Solutions to
Operations and Reforestation Monitoring Systems-
STORMS 1981). For those actions required in
timber sale contracts, the final determination of
treatment needs would be made during timber sale
planning.
Contracts, usually awarded on a competitive basis,
are the means of accomplishing all timber harvest
and many forest development practices. The
standard and special provisions (which include
mitigating measures) in a contract set forth the
performance standards to be followed by the
contractor in carrying out the action in accordance
with applicable laws, regulations and policies. In
contract preparation, selection of special
provisions is governed by the scope of the action
to be undertaken and the physical characteristics
of the specific site. The standard provisions of the
basic timber sale contract, Bureau Form 5450-3,
are applicable for all timber sales. Limitations on
timber harvesting and related activities, as
identified in the Church Report (U.S. Congress,
Senate 1973) and analyzed in the BLM Timber
Management - Final EIS-1975, have been adopted
by BLM. Bureau manuals and manual supplements
provide a variety of approved special provisions for
use, as appropriate, in individual contracts. The
combination of selected special provisions
constitutes Section 41 of the timber sale contract
(Form 5450-3).
Prior to any vegetative or ground manipulation,
BLM requires a survey of the project site for plants
and animals listed or proposed for listing/as
threatened and endangered species. If a project
might affect any federally listed or proposed
threatened or endangered species or its critical
habitat, every effort would be made to modify,
relocate or abandon the project in order to obtain
a no effect determination. If BLM determines that a
project cannot be altered or abandoned,
consultation with the U.S. Fish and Wildlife Service
would be initiated (50 CFR 402; Endangered
Species Act of 1973, as amended).
Whenever evidence of historic or prehistoric
occupation is identified during BLM activities,
special surveys are undertaken to determine
possible conflicts in management objectives. In
addition, a Class III (complete) cultural resources
inventory is required on all areas to be subjected
to ground disturbing activities. This is
accomplished in the pre-planning stage of a
treatment and the results analyzed in the
environmental assessment addressing the action
(BLM Manual 8100, Cultural Resources
Management). When a cultural resource is
discovered during timber harvest or associated
activities, operations in proximity are immediately
suspended and may only resume upon receipt of
written instructions from the authorized BLM
officer. Procedures under 36 CFR 800 would then
be followed, including consultation with the State
Historic Preservation Officer in the determinations
of eligibility and effects.
17
Transportation System
Oregon Manual Supplement, Release 5-115 of
April 10, 1975, would be used in preparing road
construction requirements for timber sale
contracts. Engineering terminology and types of
construction equipment are defined in the manual
supplement and specifications for all aspects of
construction, reconstruction and surfacing are
provided.
Methods of slope protection are provided to avoid
collapse of cut-and-fill embankments.
Specifications for rock pits and quarries include
provisions for minimum visual intrusion, drainage
and control of runoff and restoration following
use.
Special stipulations are provided for the
installation of stream crossing structures, such as
corrugated metal culverts, so that fish passage is
not impeded. These measures may include
imposing gradient limitations for the structures
and/or installing baffles to reduce water velocity
through the culverts.
One section of the manual supplement provides
design features to control and minimize erosion
during road construction and throughout the
design life of the road. Another section addresses
soil stabilization practices, including planting,
seeding, mulching and fertilizing for establishment
of soil-binding vegetation.
Road reconstruction is proposed for all
alternatives. The miles of road to be reconstructed
range from 641 under Alternative 1 to 191 miles
under Alternative 8 (Table 1-2). Similarly, the miles
of new, permanent road to be constructed during
the decade would range from 928 miles under
Alternative 1 to 277 miles under Alternative 8
(Table 1-2). Construction standards, i.e., stream
crossing, subgrade width, ditch, cut-and-fill slope
requirements, and type of surfacing, would be
determined during the annual timber sale planning
process. Basic construction operations as well as a
brief history of transportation systems are
described in detail in the programmatic
environmental impact statement BLM prepared on
timber management in the western United States
(USDI, BLM 1975), hereafter referred to as the
BLM Timber Management FEIS.
Road closures are planned for all alternatives
where significant impacts to wildlife are occurring
or likely to occur as a result of uncontrolled
vehicle access.
Timber Harvest
The primary timber harvest method to be
employed during the next 10-year period would be
clearcutting. An estimated 78 percent of the
proposed final harvest by clearcutting (see Table
1-2 for proposed acreages by alternatives) would
be accomplished by high lead cable yarding
systems. Another 9 percent would be
accomplished by cable yarding systems
specifically providing partial log suspension and 5
percent providing full log suspension. The
remaining 8 percent would be harvested by tractor
skidding, of which 19 percent would be
accomplished using "low ground pressure"
equipment. This variety of logging systems is a
design feature employed primarily for watershed
protection and reduced soil damage. Refer to the
BLM Timber Management FEIS for a detailed
description of logging systems.
Timber harvesting limitations pertaining
specifically to clearcutting, as identified in the
Church Report (U.S. Congress, Senate 1972), have
been adopted by BLM. These limitations are
incorporated in the Oregon Manual Supplement
5424, which lists special provisions or stipulations
for use in the logging requirements portion of a
timber sale contract.
Acreages allocated to the constrained timber base,
including those managed under modified area
control, would be harvested by individual tree
selection, shelterwood and/or clearcutting
methods. (Also, see discussion on Modified Area
Control in Appendix C.)
Single tree selection would be employed for
harvest of dead and dying timber (mortality
salvage) in stands not scheduled for harvest within
the 10-year period. Mortality salvage would take
place on lands in the intensive timber production
base and on all other lands in the event of a major
catastrophic event or when beneficial to wildlife or
fish. The variance in acreages proposed for
mortality salvage (Table 1-2) reflects the
differences in over-mature timber available under
each alternative.
Commercial thinning would be applied to
intensively managed timber stands between the
ages of 30 and 60 years. The interval of treatment
(ranging from 10 to 30 years) would vary
according to site characterization with poor sites
having longer intervals. Acreages proposed for
commercial thinning by alternative are presented
in Table 1-2.
Site Preparation
Site preparation procedures are used to
prepare newly harvested and inadequately stocked
areas for the planting of a new crop of trees. Four
types of site preparation treatments (broadcast
burning, herbicides, mechanical and manual) are
planned within the SYUs for the proposal period
(Table 1-2).
The main site preparation treatment would be
broadcast burning to control competing
vegetation, provide planting site accessibility and
reduce the fire hazard. Burning would occur at
18
times approved by the Oregon State Department
of Forestry which administers the Smoke
Management portion of the State's Air Quality
Implementation Plan. Acreage requiring slash
disposal by broadcast burning (Table 1-2) may
receive one or more of the following site
preparation treatments.
Site preparation treatment using herbicides (Table
1-4) is included in all alternatives except
Alternative 7. Herbicides are used to increase
plantation survival rate by control of grasses,
forbs, brush and noncommercial tree species.
These treatments improve the potential for
success by reducing competition for light,
Table 1-4 Estimated Ten-Year Use of Herbicides
Chemical
Method
Season
Carrier
Target Species
Application
Rate 1
(Ibs./Acre)
Estimated Ac
res
Alt. 1
Max.
Tbr.
Alt. 2
Emp.
Tbr.
Alt. 3
Lo
MHS
Alt. 4
OPA
Alt. 5
No
Action
Alt. 6 Alt.
HD
7- Alt 8
Full
Eco.
Alt. 9
NPA
SITE PREPARATION
Atrazine-
Dowpon
Aerial
Spring
Water
Annual & Perennial grasses
4 lbs ea
33.302
30.624
29.498
28.698
22.089
21.093
9 931
28 471
Atrazine
Dowpon-
2.4D
Aerial
Spring
Water
Grasses, lorbs. brush
•1 4 2 lbs
4,315
3.968
3.822
3,718
2,862
2.733
1.287
3.689
Velpar
Aerial
Spring
Water
Grasses, torbs
1 lb
6.563
6,036
5.813
5,656
4,353
4.157
1.957
5.611
Velpar
Aerial
Spring
Water
Annual & Perennial grasses
& forbs
2 lbs
3,525
3,241
3.122
3,037
2,338
2.233
1.051
3,013
Roundup
(Glyphosate)
Aerial
Spring
Water
Annual & Perennial grasses
& forbs
1 qt (1 lb)
425
391
377
367
282
270
127
364
Roundup
Aerial
Late
Summer
Water
Deciduous brush & hardwoods
1-1 2 qls
(1-1/2 lb.)
8.812
8.103
7.805
7.593
5.845
5,581
2,628
7.533
Garlon 4
Aerial
Early
Summer
Water
Brush & other herbaceous
vegetation
4-8 lbs.
912
838
807
786
605
577
272
780
Roundup
Ground
(back-
pack)
Spring
Water
Annual & Perennial grasses
1% solution
(1 Ib/ac.
approx )
668
615
592
576
443
423
199
571
Roundup
Ground
(back-
pack)
Spring
Water
Annual & Perennial grasses
& forbs
2% solution
(1 lb ac
approx I
2.248
2.068
1,992
1.938
1.491
1.424
671
1,923
PLANTATION
MAINTENANCE &
RELEASE
Atrazine-
Dowpon
Aerial
Spring
Water
Annual & Perennial grasses
4 lbs ea.
12.154
11 177
10,766
10,474
8.062
7,698
3,624
10.391
Atrazine
Dowpon-2.4-D
Aerial
Spring
Water
Annual & Perennial grasses,
brush & hardwoods
4/4/2 lbs.
2.478
2.278
2.195
2.135
1.643
1.569
739
2.118
2.4-D
Aerial
Spring
Water &
Oil
Evergreen brush & hardwood
species, Herbaceous
vegetation
3 lbs
3,973
3,654
3,520
3.424
2.636
2.517
1,185
3.397
Roundup
Aerial
Late
Summer
Water
Deciduous brush &
hardwoods
1 1 2 qts
12.949
11.908
1 1 .469
11.158
8.589
8.202
3.861
11.070
Velpar
Aerial
Spring
Water
Annual & Perennial grasses
& forbs
1-2 lbs
5.282
4.857
4,679
4.552
3.504
3.346
1.575
4.516
Asulox
Aerial
Late
Summer
Water
Bracken fern
3,3 lbs
(1 gal.)
3.272
3,009
2.898
2.820
2,170
2.073
976
2.798
Garlon 4
Aerial
Spring
Water &
Oil
Evergreen & deciduous
brush & hardwoods
1-2 lbs.
3.319
3.053
2.939
2861
2,201
2,102
990
2.838
Garlon 4
Ground
All
Seasons
Diesel
Bigleaf maple
(Basal Spray)
1% Solutton-
1 gal 100 gal
mix (4 Ibs./ac
approx )
473
456
443
341
326
153
439
Garlon 3A
Hand
All
Seasons
Dilute
with
water
i 1
Bigleaf maple. Madrone.
Red alder (hack'squirt)
1 ml Solution
per inch dia
approx .)
1.075
989
952
927
713
681
321
920
Tordon 101 R
(picloram-
2.4-D)
Hand
Spring
None un-
diluted
Madrone & other hardwoods
1 ml. per Inch
dia
lb ac )
1.590
1.532
1.490
1 147
1.095
516
1 478
' Active ingredients (in total pounds) applied may be figu
alternative.
red by mult
iplying the application rate by the
estimated acres under each
* Alternative 7 does not em
ploy the
use of herbicides.
19
moisture and soil nutrients during the tree
seedling establishment period. Application and
monitoring of herbicides would be in accordance
with BLM's FEIS Vegetation Management with
Herbicides: Western Oregon 1978 through 1987.
See the following Plantation Maintenance and
Release section for more detail. Alternative 7,
which does not incorporate herbicide use,
employs the manual method of paper mulching on
slopes less than 65 percent.
Manual site preparation would occur on some
acreage during the next decade (Table 1-2).
Treatments would consist of paper mulching,
scalping or brush cutting and piling for burning.
Mechanical site preparation would consist of
scarification and piling or windrowing of slash,
brush and unmerchantable stems. Bulldozers
equipped with a brush blade would normally be
used. However, this type of equipment would be
restricted to areas with slopes less than 35
percent, low soil moisture conditions and suitable
soil types.
Planting
To achieve adequate reforestation within
five years following harvest on timber production
lands, harvested areas would be planted with
commercial coniferous species (Douglas-fir, grand
fir, incense cedar, Jeffrey pine and ponderosa
pine) within one year of the completion of site
preparation. Planting stock is nursery grown from
seed collected on sites and at elevations similar to
the specific project area. Genetically improved
stock is also being nursery grown and would be
scheduled for planting on 15,200 acres. The broad
selection of parent trees for genetically improved
stock is intended to maintain genetic diversity
(BLM Instruction Memorandum OR 79-334).
Reforestation experience in the Roseburg SYUs
shows that target stocking levels of 245 to 320
trees per acre, depending on site class, cannot
always be achieved by the initial planting. Post-
treatment surveys would be conducted to
determine the rate of survival and when replanting
or interplanting would be required to meet
stocking standards.
Plantation Protection
Estimated acreages that would require some
type of protective treatment are shown in Table 1-
2. Treatments would include proteotion from the
sun by shading and placing plastic tubing or
netting over seedlings to protect them from
damage by deer, elk, porcupine or other small
animals. Porcupine would be trapped when they
occur in significant numbers in a plantation. The
total number of acres requiring each of these
treatments would be determined in conjunction
with normal reforestation surveys.
Plantation Maintenance and
Release
Maintenance treatments promote the survival
and establishment of coniferous seedlings.
Release treatments reduce competition for light,
moisture and nutrients between shrubs or grass
and existing commercial coniferous seedlings and
promote dominance and growth of established
coniferous trees.
In recent harvest areas, grass, forbs, shrubs and
hardwoods often suppress the growth of conifer
seedlings. The degree and type of competition
varies with the individual site. On dry sites, grass,
forbs and shrubs are strong competitors for water,
while elsewhere hardwoods grow rapidly enough
to shut out essential light and compete for water
during the dry summer. With reduced competition,
the conifers rapidly grow beyond the point where
they can be overtopped and further suppressed by
surrounding vegetation. When this growth
situation is achieved (approximately 3 to 10 years
from planting), there would be no further control
of competing vegetation necessary.
Each area proposed for maintenance or release
treatment would undergo a site specific
environmental assessment. During this analysis,
alternative methods of vegetation control are
considered, including chemical, manual and
mechanical means. Assessments addressing
specific herbicide projects are prepared and tiered
under BLM's FEIS Vegetation Management with
Herbicides: Western Oregon - 1978 through 1987.
In recent years, herbicides have been used
effectively to inhibit the growth of competing
vegetation, thus increasing available water,
nutrients and light for suppressed conifers.
Herbicides are applied aerially or by several
ground methods. The method selected is
dependent on costs, topography, limits of the
equipment, kind and dispersion of target plants,
potential environmental impacts and biological
conditions. Most herbicide applications in the
Roseburg SYUs would be by helicopters equipped
with positive shut-off spray systems to limit
herbicide aplication to the target areas. Helicopter
application would be accomplished under contract
through the competitive bidding process.
Timing of herbicide treatment is stringently
controlled in relation to specified weather
conditions such as temperature, humidity and
wind. There is full authority for ordering cessation
of operations based on adverse field conditions.
Both equipment and operators are frequently
checked by field project supervisors. Only
registered chemicals would be used and in
accordance with labeled instructions on the
container. Handling, storage and application of
chemicals would be in accordance with the
20
Oregon Forest Practices Act (see the
Interrelationships section, State and Local
Government).
Protective stream buffers (determined according
to stream classification and herbicide used) and
monitoring of herbicide application are as
described in the FEIS mentioned above.
Continuous administration of spraying contracts in
progress is required. Water samples of selected
streams would be taken prior to spraying to
establish baseline quality and at specified intervals
thereafter.
The use of herbicides for plantation maintenance
and release is included in all alternatives except
for Alternative 7 (Table 1-2). Table 1-4 shows the
chemicals, target species and estimated acreage of
herbicide use as proposed during the 10-year
period.
Precommercial Thinning
Under all alternatives except Alternative 8,
precommercial thinning would be applied to
timber stands between 10 and 20 years of age
which contain over 500 stems per acre (estimated
to be 60 percent of the stands). This treatment
concentrates available nutrients, moisture and
light into those trees which would be the eventual
crop for future harvest.
The number of trees cut per acre during
precommercial thinning is dependent on the
density of the stand before thinning. While average
spacing is approximately 12 feet, the number of
crop trees left may vary between 245 and 320 per
acre. Contract specifications, emphasized by field
instructions to crews, cover desired spacing of
crop trees and criteria for crop tree selection.
Fertilization
Areas precommercially and commercially
thinned and portions of areas where stocking
control was achieved through plantation spacing
would be fertilized (Table 1-2) except in
Alternatives 5, 7 and 8. Continuing studies and
analysis will be conducted to determine fertilizer
response and economic effectiveness of planned
projects. The average application is expected to be
200 pounds of nitrogen per acre. Stands would be
fertilized when precommercially thinned,
commercially thinned and at 10-year intervals
thereafter until 10 years before final harvest. In
addition to acceleration of growth for up to seven
years following treatment, fertilization reduces
shock associated with thinning.
Comparison of Impacts
This section compares in tabular form (Table
1-5) the impacts of each alternative, including the
New Preferred Alternative (Alt. 9) and the Original
Proposed Action (Alt. 4). While impacts have been
described in detail in Chapter 3, Table 1-5 is
presented to assist decisionmakers and reviewers
by summarizing the impacts of each alternative,
thereby permitting major issues to be defined and
analyzed.
Two areas of major impacts are wildlife habitat and
economic conditions. The greatest total habitat
modification would occur in Alternative 1. The
greatest old growth habitat modification would
occur in Alternative 5, where about 70 percent of
old growth habitat would be removed by the end of
the first decade. Alternative 8 would result in an
increase of old growth habitat over the long term;
all other alternatives would result in long-term
decreases of old growth habitat.
Alternative 1 would be most beneficial to the
economic situation, providing about 1,500 more
jobs than would be provided by continuation of the
existing program. Alternative 8 would have the
greatest adverse impact, providing approximately
2,000 fewer jobs than would a continuation of the
existing program (Alternative 5).
Other areas of impact are soil erosion and
sediment yield. Alternative 1 would cause the most
erosion; Alternative 8 the least. Cumulative
sediments produced as a result of timber
management activities would increase from levels
in the past decade by 26 percent in Alternative 1
and decrease by 100 percent in Alternative 8 where
no new sedimentation is expected. Alternative 8
would have the least adverse impacts attributable
to either soil erosion or sediment yield.
Implementation
Final Decision
After release of the final EIS (and
following the comment period) the District
Manager will review the public comments on both
draft and final EISs and prepare a Record of
Decision. The recommended decision may be to
select one of the EIS alternatives intact, or to blend
features from several alternatives that fall within
the range of actions analyzed in the EIS. The final
decision will be made by the State Director.
Significant conflicts, alternatives, environmental
preferences and economic and technical
considerations will be addressed in the Record of
Decision, which is expected later in 1983.
Monitoring and Studies
BLM land management programs are monitored
in various ways. Currently, forest management
practices are monitored primarily through
administration of the contracts under which most
actions are authorized. Timber sale contracts are
inspected at least once a week, when active, and
more often if sensitive operations are in progress.
21
Table 1-5 Si
Environmental Components
immary
Units of
of In
Existing
npac
All. 1
Is
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Alt. 6
All 7
Alt. 8
Alt. 9
Impacted
Measure
Situation
Max. Tbr.
Emp. Tbr.
Lo MHS
OPA
No
Action
HD
No Herb.
Full Eco.
NPA
Remarks
Air Quality
Nitrous oxides
tons/year
365
335
323
314
242
231
217
109
312
Hydrocarbons
tons year
NA
2,279
2,096
2,019
1.964
1.512
1,443
1,353
680
1.948
Particulates
tons/year
3.828
3,521
3,391
3.299
2,539
2,425
2.274
1,142
3.273
Soils
Lost productivity
acres/decade
NA
3.568
3,283
3.150
3.072
3.143
2.260
2,141
985
3.071
+es roads.
Water Resources
Sediment yield
tons x 100/
decade
NA
4,915
3,151
2,813
2.728
2.772
993
1.883
429
1.235
Vegetation
Acres denuded
Road construction
acres, decade
3,553
5,568
5.124
4.932
4.800
3.696
3.528
3.306
1.662
4.764
Plant habitat altered by
Herbicide use
acres-'decade
41,231
107,516
98,872
95,234
92.653
71,314
68,100
32.063
91.920
Timber harvesting
acres/decade
75.004
74.807
68,852
65.956
64.374
73,600
47,438
45.107
19,915
61,804
Wildlife Habitat
Habitat modified
acres decade
NA
125.000
116.200
111,600
109.900
89.600
82,300
85.700
21.600
107.000
Roads, harvest and thinning.
Early successional
acres
75.000
97.400
92.000
89,700
88.100
71.800
73,300
71.000
51.600
87 800
Habitat < 15 years old
stage habitat, end
1st decade
Early successional
acres
75,000
134.000
74.300
119,500
71,700
72,600
51.000
71.100
37,400
100,500
Habitat 15 years old
stage habitat, end
10th decade
Old growth habitat,
acres
110,900
66.500
70,600
72.400
73.600
35,000
85.800
87.600
103,200
74,400
Habitat 196 years and older.
end 1st decade
Old growth habitat.
acres
110,900
13.700
21.100
31,800
31,800
7,300
68.100
70,000
123.500
38.900
Habitat 196 years and older
end 10th decade
Wildlife Population
Roosevelt Elk, end
Percent change
NA
-25%
-25%
-25%
-25%
-10%
-5%
-20%
No
-25%
Plus or minus 5 percent.
of 5th decade,
from existing
Change
Tyee Area only
Roosevelt Elk, end
Percent change
NA
-25%
-25%
-30%
-20%
-20%
-5%
-20%
No
-20%
Plus or minus 5 percent
of 10th decade,
from existing
Change
Tyee Area only
N. Spotted Owl, end
Pairs
55
18
18
25
18
55
19
300 acre old growth
of 10th decade
management recommendation
N Spotted Owl, end
Pairs
55
24
42
1 .000 acre old growth
of 10th decade
management recommendation
Snag Dependent Wildlife
Percent of
Potential
60%
• 10%
10%
20-30%
20-30%
10%
40-50%
40-50%
70-80%
20-30%
Long term
Recreation
Ability to
meet needs
-
-L
♦ L
♦ L
♦L
-M
+ L
+ L
♦L
+ L
Cultural Resources
Inadvertent
degradation
(undiscovered
sites)
-H
-H
-M
-L
-L
-L
-L
-L
-L
Based on comparison of
harvest levels
Visual Resources
Degradation of
scenic quality
-H
-M
-M
-M
-H
-L
-L
-M
Areas of Critical
Degradation of
_
-M
-H
Enviromental Concern
resource
values
Special Areas
Site
degradation
-
•H
-L
-L
-L
-H
-L
-L
-L
-L
Energy Use
Billion Btu's
consumed
annually
~~
834
770
741
723
528
536
514
218
716
Socioeconomic '
Impacts Compared to
Existing Condition
Total earnings
$ millions
39 2
♦21 2
•166
• 14 3
+ 129
•28
•09
-2 4
-21.6
♦124
Total employment
jobs
3,225
"1,746
♦1,367
+ 1,178
+ 1.058
♦ 232
-77
-198
-1.780
+ 1.023
Public revenue
$ millions
14 2
-1 1
-2.1
-2 6
-2 9
-5 1
-5.9
-62
-10.4
-3
Based on stumpage at
S94/M bd ft
S millions
142
♦22
•193
♦17.9
• 170
• 110
•87
-7 9
-3.7
♦ 168
Based on stumpage at
S260/Mbd ft
Impacts Compared to No
Action Condition
Total earnings
S millions
42
+ 184
•138
♦11 5
•100
-38
-52
-24.5
♦9 6
Total employment
jobs
3 457
•1.514
♦1,135
•946
♦826
-310
-430
-2,012
+ 791
Public revenue
S millions
15.2
-2 1
-3 1
-3 6
-3 9
-69
-72
-11 4
-4
Based on stumpage at
S94.'Mbd ft
$ millions
15.2
•21
•183
♦169
♦160
♦ 7 7
+6 9
-4.7
+ 158
Based on stumpage at
S260 M bd ft
' See Chapter 3 for discussion of d
ual impact measures.
r- Beneficial
- Negative
L Low
M Medium H High
2 Impacts measured f
rom No Action Condition (Alternative 5).
1
^JA - Not Applicable
22
Daily administrative visits are not uncommon when
harvest is moving at a fast pace, slash disposal is
occurring, or road construction involving critical
aspects (such as stream crossing structures) is
taking place. Service contracts, i.e., tree planting,
precommercial thinning, tubing, manual brush
cutting and fertilization, are monitored at regular
intervals to determine the quality and quantity of
completed work. Visits to these operations range
from twice a week to the full-time presence of a
Bureau contract administrator, depending on the
experience of the contractor and rate of progress.
Daily visits usually occur when there is reason to
believe that the operator will require help in the
interpretation of contract requirements.
Silvicultural treatment success is monitored
through a series of inventories and surveys
performed at various times during the stand's life.
Appropriate stocking surveys are performed both
prior to and after a treatment is accomplished.
Information from these surveys identifies the need
for or success of a particular silvicultural
treatment. This information is documented and
maintained in the operations and reforestation
records systems.
Water quality monitoring would be carried out in
accordance with Executive Orders 11514 (partially
amended by 1 1 991 ) and 1 2088, Sections 208 and
313 of the Clean Water Act (PL 95-217, PL 92-500
as amended), BLM Manual 7240 and Oregon
Department of Environmental Quality
Memorandum of Understanding (MOU-OR 158).
Standard analytical methods would be followed.
Monitoring systems for other resource
management programs (wildlife habitat, visual,
cultural and recreational) outlined in the final
decision would be developed and implemented.
Requirements for Further
Environmental Analysis
This environmental impact statement may best
be described as a regional statement for the
proposed 10-year timber management plan and is
considered applicable for the decade. Site specific
environmental analysis and documentation
(including categorical exclusion where
appropriate) will be accomplished for each type of
treatment under consideration. Interdisciplinary
impact analysis will be tiered within the framework
of this and other applicable environmental impact
statements.
An environmental assessment of a timber sale (or
group of sales) will address the effects of the
harvest method, yarding system, road construction
or reconstruction, slash disposal and any other
treatments conducted under the terms of a timber
sale contract. Environmental analysis of forest
development projects such as precommercial
thinning, animal damage control, fertilization and
herbicide applications will also be accomplished.
With problems and conflicts identified through
analysis, it is possible to design the proposed
project in an environmentally sensible manner.
Where the action is to be accomplished by a
contractor, the environmental assessment is a
primary means for determining appropriate
contract stipulations. Projects to be accomplished
by BLM personnel are conducted in accordance
with the findings of the analysis and decision
documents.
If an environmental assessment indicates potential
for significant impacts not already described in an
existing EIS, an environmental impact statement or
a supplement to an existing EIS may be required.
Interrelationships
Much of western Oregon is timber producing
land. In addition to the BLM, jurisdictions include
the U.S. Forest Service, State of Oregon, the
counties, and private companies and individuals.
Each entity approaches management of timber
lands differently, although some periodically
prepare internal or public plans for their
management.
Federal Agencies
The Roseburg SYUs share in part a common
boundary with the Umpqua National Forest.
Coordination between the BLM District Manager
and the Forest Supervisor is routine. Specific
project and program coordination takes place as
needed between all management levels of each
agency and also between resource specialists. A
cooperative agreement provides for interagency
road construction and use and fire protection.
The U.S. Army Corps of Engineers has the
authority, under Section 404 of the Clean Water
Act of 1977 (P.L. 95-217), to regulate the discharge
of dredged or fill materials into any estuary,
wetland or streams of the United States with flow
in excess of five cubic feet per second. Normal
silvicultural practices are exempt from this
regulation. Based on the adequacy of BLM
environmental protection practices, the Corps has
issued BLM a general permit for all such activities.
Under the permit, BLM provides the Corps, the
State Division of Lands and certain environmental
review agencies with advance notice of specific
proposed projects. Larger projects exceeding
limits in the general permit require a separate
permit.
The U.S. Fish and Wildlife Service administers the
Endangered Species Act of 1973 (as amended).
Accordingly, BLM consults with that agency when
it is determined that a threatened or endangered
species or its critical habitat may be affected. The
purpose of consultation is to obtain expert advice
on the appropriate course of action. The outcome
of such consultation may mean modification or
abandonment of the action.
23
The National Marine Fisheries Service (NMFS) is
responsible for oversight and evaluation of
activities which may affect marine, estuarine, and
anadromous fishery resources. NMFS participates
in comprehensive land and water use planning
under the terms of the Water Resources Planning
Act, the Coastal Zone Management Act, and the
National Environmental Policy Act and makes
recommendations for maintenance or
enhancement of anadromous fishery resources
under the terms of the Fish and Wildlife
Coordination Act.
The Soil Conservation Service (SCS) is
responsible for all aspects of the National
Cooperative Soil Survey. Accordingly, BLM has a
cooperative agreement with SCS that provides for
the development and utilization of soil surveys on
lands that are of interest to the Bureau. The soil
survey data will provide a basis for efficient
interpretations for the Bureau planning and
management systems.
The National Park Service (NPS) administers the
Nationwide Rivers Inventory, as provided under
the National Wild and Scenic Rivers Act of 1968.
Present efforts are directed toward inventory and
evaluation to determine which free-flowing rivers
and river segments are suitable for possible
designation as components of the National Wild
and Scenic Rivers System. BLM consultation with
NPS is required if proposed management actions
could alter a river's ability to meet established Wild
and Scenic Rivers Act eligibility and/or
classification criteria.
State and Local Governments
Section 202(c) of the Federal Land Policy
and Management Act requires BLM to coordinate
its planning efforts with those of State and local
governments; assist in resolving inconsistencies in
our mutual planning efforts; provide for State and
local governmental involvement in development of
BLM land use programs, regulations and land use
decisions; and develop BLM resource
management plans and programs consistent with
those of State and local government to the extent
that such BLM plans and programs are also
consistent with Federal law and regulations. BLM
coordination efforts involve a number of State and
local administrative and planning agencies as
highlighted below.
The Intergovernmental Relations Division for the
State of Oregon is the clearinghouse for the
various State agencies. Notice of all BLM planning
and major proposed actions are provided for
coordinated State level review by the State
Clearinghouse. The Regional Councils of
Government serve as the clearinghouse for
coordinated review of proposed BLM activities by
county and local governments in their respective
areas of interest. BLM involvement with the three
counties in the SYUs is largely via the boards of
county commissioners. Through these bodies,
county governments participate in planning for
land use, road construction and recreational
developments on public lands administered by
BLM.
The Oregon Land Conservation and Development
Commission (LCDC) administers the state
comprehensive land use planning program as
provided in Oregon State Statutes, Chapter 197
(ORS 197). In this program, county and local
governments are required to develop
comprehensive land use plans and implementing
ordinances consistent with 14 statewide planning
goals and guidelines. These call for a balance
between conservation and development to best
meet public needs.
Close relations have been established with LCDC
to ensure cooperation and coordination of BLM
programs and planning efforts with those
conducted by county and local governments under
ORS 197. The relationship of the Roseburg
alternatives to the LCDC Statewide Goals is shown
on Table 1-6. Discussion comments on this table
generally focus attention on deficiencies in
addressing the listed goals.
Throughout the planning process, BLM has
worked with Douglas County to achieve
consistency with local plans. Methods of involving
local governments have included: (1) frequent
informal contacts to discuss local planning
concerns; (2) invitations to participate in public
tours, workshops and meetings; and (3)
discussions with the Douglas County Planning
Department to determine consistency of BLM's
preferred land use plan with acknowledged local
plans.
The Comprehensive Land Use Plan for Douglas
County was adopted by the Douglas County Board
of Commissioners in 1981 and was recently
accepted by LCDC. To meet the decision factor
regarding consistency with State and local land
use plans, the Original Proposed Action and New
Preferred Alternative were developed to be
consistent with the recently adopted
Comprehensive Land Use Plan of Douglas County.
24
Table 1-6 Relationship of Roseburg EIS Alternatives to LCDC Statewide Goals 1
LCDC Statewide Goal
Number and Description Discussion 2
1. To insure citizen involvement in all BLM land use planning process provides for public
phases of the planning process. input at every stage — from assistance in the initial
inventory to the identification of management
opportunities, the development of alternatives, the
environmental analysis and the final decision.
2. To establish a land use process and
policy framework as a basis for all
decisions and actions.
4. To conserve forest lands for forest
uses.
5. To conserve open space and protect
natural and scenic resources.
6. To maintain and improve the quality of
the air, water and land resources.
7. To protect life and property from natural
disasters and hazards.
8. To satisfy the recreational needs of the
citizens of the State and visitors.
9. To diversify and improve the economy of
the State.
12. To provide and encourage a safe,
convenient and economic transportation
system.
13. To conserve energy
All alternatives have been developed in accordance with
the land use planning process authorized by the
Federal Land Policy and Management Act of 1976
which provides a policy framework for all decisions and
actions.
The planning area is predominately forest land. All
alternatives provide retention of inventoried forest lands
for forest users. No alternative exceeds the productive
capacity of the land base and all proposed uses are
compatible with forest uses.
All alternatives conserve open space and protect
mineral and cultural resources and T&E species. All
alternatives except 1 protect scenic resources, wildlife
habitat, natural areas and riparian areas to some
degree.
Only Alternative 1 does not fully address necessary
enhancement of land and water quality for multiple use
of forest lands or for meeting Federal and State
minimum water quality standards. Slash burning will
increase smoke (see Table 3-1). All alternatives would
comply with the statewide smoke management plan.
All alternatives include identification of potential hazard
areas and general BLM program and operational
measures for protection of life and property from
natural disasters and hazards.
Alternative 1 emphasizes those activities having
minimal impact on the commercial timber base.
Alternatives 2, 3, 4, 7 and 9 provide a variety of
developed and dispersed recreation opportunities to
meet most recreational needs. Alternatives 6 and 8
provide for dispersed activities, natural areas and
developed sites in some areas. Alternative 5 would
continue the existing situation. Alternatives 1 and 5
would fail to adequately meet some increasing needs
for areas and facilities.
Alternatives 1 and 2 would increase timber production,
but lack diversity in that limited allocations would be
provided for non-timber values. Alternatives 3, 4 and 9
provide diversity and increase total economic returns.
Alternative 5 maintains status quo while Alternatives 6,
7 and 8 provide diversity but result in decreases in total
economic returns.
The forest transportation system will be expanded and
improved.
Conservation and efficient use of energy resources are
objectives in all BLM activities.
1 LCDC goals not generally applicable to the proposal and alternatives are: 3. Agricultural lands: 10. Housing; 1 1 . Public Facilities and Services:
14. Urbanization; 15 Willamette Greenway: All Coastal Zone Goals
' See Chapter 3 and Table 1-5 for impacts of the alternatives on the various resources. Also see the Index and Table of Contents for specific page
numbers to specific resources.
25
The Oregon State Forester, by means of the Forest
Practices Act of 1972, regulates timber harvest
methods and supportive practices on all non-
federal lands within the SYUs. Minimum standards
are prescribed relating to the following forest
practices:
• Timber harvesting.
• Reforestation of economically suitable lands.
• Road construction and maintenance on forest
land.
• Chemical applications.
• Slash disposal.
• Maintenance of streamside buffers.
Although Federal agencies are not bound by State
forest practice rules, Bureau minimum standards
meet or exceed State rules. The BLM and USFS,
acting jointly, have entered into a Memorandum of
Understanding (MOU) with the State Forester in
this regard.
BLM is a cooperator in the Statewide Smoke
Management Plan administered by the Oregon
State Forester in order to comply with the Clean
Air Act of 1963 (as amended). The primary
objective of the plan is to keep smoke from slash
disposal operations away from population centers.
Slash burning is allowed to begin only when
smoke dispersion conditions are determined by
Oregon State Department of Forestry (OSDF) to
be favorable.
OSDF is the primary contractor for fire protection
of public lands administered by BLM in the SYUs.
That department undertakes presuppression and
suppression actions for all lands in the area.
The Forestry Program for Oregon (Oregon State
Board of Forestry 1977) outlines basic objectives
of the Oregon State Board of Forestry for timber
land management within the State. The
relationship of the nine alternatives to these basic
objectives is shown in Table 1-7. For the decade
beginning in 1980, BLM harvest projections to
meet Forestry Program for Oregon targets is 245.4
MM bd. ft. annually.
Management of wildlife, including fish, within the
SYUs is the responsibility of the Oregon
Department of Fish and Wildlife. The Sikes Act (PL
93-452) as amended is the primary tool guiding
coordination between BLM and ODFW. BLM, in
managing lands under its jurisdiction, considers
wildlife habitat as a resource category. A master
Memorandum of Understanding with supplemental
cooperative agreements describes the mutual
responsibilities of the two agencies. Oregon
Revised Statue 496.012 established goals for the
management of the State's wildlife. The
Table 1-7 Consistency of the Roseburg Alternatives with the Basic
Objectives of the Forestry Program for Oregon 1
ALTERNATIVES
Basic Objective
Consistent
Minimally
Consistent
To maintain the maximum
potential commercial
forest land base
consistent with other
resource uses while
assuring environmental
quality
To maintain or increase
the allowable annual
harvest level to its
fullest potential to
offset potential
socio-economic impacts.
To identify and implement
the levels of intensive
forest management required
to achieve maximum growth
and harvest
To maintain community
stability by remaining
flexible for increases in
future harvest levels that
would offset proiected
shortages
Inconsistent
2.3,4,6.7.8.
9
1 .2,3.4,5,9
6.7.8
1.2.3,4,6.9
1.2,3,4,9
5,6,7.8
Discussion
The benchmark (391.070 acres) for consistency
is the commercial forest land base minus
withdrawn TPCC lands Environmental quality
would be protected to the degree specified in
the Oregon Forest Practices Act. However.
Alternative 1 would not meet management
guidelines for certain lands as mandated by
Congressional Acts and Federal Executive
Orders (see Purpose and Need Section) because
of impacts on riparian zones.
The benchmark for consistency is the current
allowable cut volume of 201 MM bd. ft. per
year The level of cutting the land base can
sustain is dependent on number of acres
allocated to timber production, level of
management the land base receives and
productivity of the land
BLM currently implements a full range of
intensive timber management practices (refer
to Forest Management Treatments and Design
Elements, this chapter) for optimization of
timber production. New and improved practices
would be implemented consistent with
technological advances
The benchmark for consistency is the Roseburg
District cooperative harvest target of 245 MM
bd ft.. Yr.' as determined by OSDF
1 Arrived at through consultation with Oregon State Department of Forestry.
2 Oregon State Forestry Department, 1980.
26
consistency of the EIS alternatives with these
goals is shown in Table 1-8.
The Oregon Department of Environmental Quality
(ODEQ) has lead responsibility for statewide water
quality management planning in accordance with
Section 208 of P.L. 92-500 (Federal Water Pollution
Control Act) as amended by P.L. 95-217 (Clean
Water Act). BLM and ODEQ have entered into a
Memorandum of Understanding which outlines
their respective roles in meeting State water
quality objectives. The MOU assures close
interagency cooperation, development and
implementation of appropriate practices and
control measures to comply with the Clean Water
Act, and compliance with State requirements. BLM
forest management practices meet or exceed
objectives of the statewide water quality
management plan.
The cities of Canyonville, Drain and Riddle have
signed Memoranda of Understanding with the
BLM Roseburg District. These MOUs identify
lands within municipal watershed boundaries and
describe practices to be incorporated during
timber management activities to maintain water
quality. There are additional MOUs with a variety
of agencies addressing resources within the
Roseburg District.
Table 1 -8 Consistency of the Alternatives with State of Oregon Wildlife Goals
Minimally
Goal
Consistent Consistent Inconsistent
Discussion
To maintain all species of
1-9'
In the short term all alternatives would provide
wildlife at optimum levels
habitat sufficient to retain a representative
and prevent the serious
8 } 6 1-5. 7 and 9
ecosystem and "prevent the serious depletion of
depletion of any
any indigenous species" Only Alternative 8 would
indigenous species
fully provide optimum long-term levels, although
Alternative 6 would provide habitat at minimum
viable levels for all species in the long term.
To develop and manage the
1-9'
In the short term habitat diversity would
lands and waters of the
increase such that production and public
State in a manner that
6, 8 ? 2. 3, 4. 7 1 and 5
enjoyment of wildlife would be enhanced by all
will enhance the
and 9
alternatives In the long term Alternatives 6 and
production and public
8 would provide for all species, while
enjoyment of wildlife
Alternatives 2, 3, 4. 7 and 9 provide for
enhancement and enjoyment of wildlife, but not
for all species and at levels below optimum.
Alternatives 1 and 5 would only enhance early
serai stage species in the long term
To develop and maintain
1 -9.-
All alternatives provide for public access
public access to the lands
through an extensive road network over both the
and waters of the State
short and long term.
and the wildlife resources
thereon.
' Short-term (First decade)
2 Long-term (Beyond first decade)
27
Chapter 2 Affected
Environment
m _i
This chapter addresses the environment as it
exists today within the Roseburg Sustained Yield
Units (SYUs). In the SYUs there are approximately
424,000 acres of BLM managed lands, of which
404,000 acres are forested. On approximately
169,000 acres (40 percent), timber harvest has
occurred for several decades, and the environment
described exhibits the effects of human use. On
about 255,000 acres (60 percent), there has been
no past timber management, although
interspersed non-public lands have been managed
for timber. Within this area there are approximately
111,000 acres of 200-year-plus old growth on
scattered tracts of public land.
Chapter 2 provides a basis on which impacts of all
the alternatives may be assessed. Data and
analysis will be commensurate with the
importance of the impact, with less important
material summarized, consolidated or simply
referenced.
In preparation of this chapter, the primary data
sources are documents of the Bureau planning
system developed by the Roseburg District. The
Unit Resource Analysis (URA), Planning Area
Analysis (PAA) and proposed Management
Framework Plan (MFP) for the Roseburg area are
available for review at the Roseburg District Office
of BLM in Roseburg, Oregon.
28
Other references supplementary to or updating
planning system data are cited within the body of
the text by author and date of publication. A listing
of these references appears in the References
Cited.
Climate and Air Quality
The area has a temperate marine climate with
warm summers and mild, wet winters. In
Roseburg, the mean maximum temperature is
84° F, the mean minimum is 33° F. The record
high was 109° F in 1946 and the record low was
-6° in 1888. During summer days, soil
temperatures have been found to exceed 160° F.
Monthly precipitation, mostly as rain, ranges from
5.46 inches in Riddle and 8.89 inches in Reston
during January to less than 0.3 inches during July.
Average precipitation is about 45 inches annually
in the Roseburg SYUs. The maximum recorded
was 60 inches at Twelvemile Creek. Snow may
block roads in some winters, but snow is generally
short-lived.
Air movement patterns are predominately from the
north (U.S. Department of Commerce, Weather
Bureau, Cited in USDI, BLM 1980a), except during
the late fall and early winter months (November,
December, January), when winds are southerly.
Mean yearly wind speeds in Roseburg are 4.5
miles per hour.
During the late summer and fall months, the
valleys and interior hills of Douglas County are
subject to frequent night-time inversions—cool air
stabilizing below warmer air above. Specific
information on the extent and duration of these
conditions within the area is not available.
Under the Clean Air Act Amendments of 1970,
Oregon has been divided into five Federal Air
Quality Control Regions (AQCRs) on the basis of
pollution concentrations, geography and
economics. The EIS area is in the southwest
Oregon AQCR. Air quality in this area is good and
meets all air quality standards (ODEQ 1981 ).
Provisions of the Clean Air Act Amendments of
1977 were made to ensure that areas with clean air
do not suffer deteriorating air quality. Mandatory
Class I areas are Crater Lake National Park and
Diamond Peak, Kalmiopsis, Mt. Washington, Three
Sisters, and Mt. Jefferson Wilderness areas. The
SYUs and surrounding areas are designated Class
II, which allows only moderate deterioration of air
quality.
The only sampling site within the EIS area is
located in Roseburg. Since 1971, total suspended
particulate levels have exceeded secondary
Federal health standards (more than 150
micrograms per cubic meter (ug/m 3 )) 14 times and
have once violated primary standards (more than
260 ug/m 3 ) (ODEQ 1981). The annual geometric
mean for total suspended particulates has ranged
from 64.7 micrograms per cubic meter (ug/m 3 ) in
1974 to 46.0 ug/m 3 in 1980 (ODEQ 1981). See
Table 2-1.
Occasionally, smoke from slash burning in the
SYUs has been visible in the population centers of
Roseburg and Eugene-Springfield (ODEQ 1981).
Slash smoke problems (visible smoke) in Douglas
County are shown in Table 2-2.
Table 2-1 Total Suspended Particulates in Roseburg
(mic
rograms per cu
bic
meter,
ug/m
3 )
Days
Exceeding
Annual
No. of
Standards
Geometric
24 Hour
Averages
Year
Samples
150
260 1
Mean
Maximum
2nd Highest
1971
98
2
51.2
185
180
1972
88
2
59.3
222
162
1973
58
4
52.9
233
181
1974
57
4
1
64.7
263
258
1975
52
43.9
93
89
1976
51
47.8
140
121
1977
60
1
52.0
170
170
1978
60
51.4
104
103
1979
32
-
109
92
1980
60
1
46.0
157
137
'Secondary standard = >150 ug/m
'; primary standard = -260 i
jg/m 3 .
Source:
ODEQ 1981
29
Table 2-2 Slash Smoke Problems
in Douglas County
Year
No. of Burns
Acres
Tons of Slash
Number of Problems
Total BLM Days
1976
1977
1978
1979
1980
1981
630
601
641
603
690
141
24,986
21,542
25,617
24,103
26,507
3,742
686,523
888,965
1,042,245
909,172
756,713
51,457
14
4
9
29
1
5
12
1
3
1
Source:
ODEQ 1981;
OSDF Annual Reports
of Oregon Smoke Ma
nagement Plans, 1977 thi
-ough 1982.
Geology and Topography
The SYUs are located within the Coast Range,
the Klamath Mountain and the Western Cascades
physiographic provinces (Figure 2-1). The Coast
Range is made up of submarine basalts and
marine sediments of the Tyee and Umpqua
Formations. The Klamath Mountain province is
geologically complex, consisting of marine
sediments, plutonic and volcanic rocks that have
been folded, faulted and metamorphosed. The
topography is rugged due to the resistant type of
rock found there. Serpentine is fairly widespread
in the Klamath Mountains, and extends
northeasterly from the Cow Creek area through
the central and southern part of the SYUs. Granite
and diorite bedrock are found in several large
areas in the southeastern part of the SYUs. These
erode easily, creating steep, short sideslopes and
sharp ridges.
Also found in the Klamath Mountain province are
thickly bedded sandstone and thin interbeds of
mudstone, volcanic rock sometimes called
greenstone because of the abundance of chlorite,
and a chert pebble conglomerate overlain by
sandstone, siltstone and conglomerate. The
Western Cascade Province is characterized by a
rugged topography with irregular ridges and deep
narrow valleys. The rocks are mostly volcanics.
Intrusive rock bodies in the Western Cascades are
generally small and consist of plugs, dikes, sills
and domes.
Throughout the SYUs, slopes range from percent
to vertical and average about 60 percent. Over 40
percent of the area has slopes in excess of 65
percent. Elevations range from 150 feet at Elkton,
500 feet at Roseburg and 650 feet at Myrtle Creek
to 2,800 feet at Baughman Lookout, 3,900 feet at
Dutchman Butte, 4,400 feet at Deadman Mountain
and 4,800 feet at Huckleberry Mountain.
Soils
The "Soils of the Roseburg District" (Wert
et al. 1977) describes the soils resource of the EIS
area in detail. A generalized soils map, which
contains 14 broad groupings of soils, is shown as
Figure 2-2. This map is useful only to show a
general view of the major soils in the Roseburg
SYUs. Soil moisture and soil temperature directly
influence the ability of the soil to support plant life.
Soils within the SYUs are generally capable of
producing abundant plant growth. Most soils have
a high content of organic matter, moderate to high
nutrient levels and medium bulk densities (1.1 to
1.3 gm/cm 3 ). Soils at high elevations, however, are
often low in organic matter and nitrogen.
Dry ravelling of soil materials, landslides and soil
surface erosion occur naturally throughout the
Roseburg SYUs. Total soil loss from these factors
in the undisturbed forests is estimated to be 0.15
to 0.40 tons per acre per year (t/ac/yr). Soil loss
and loss of soil productivity have accelerated as a
result of timber harvesting and road building.
District experience has shown that in areas where
road construction and harvests have taken place
and regrowth is now established, soil loss is about
1 to 3 t/ac/yr. In typical areas where tractor
logging and downhill yarding have been practiced,
erosion is estimated to be 230 t/ac/yr initially,
reducing to an estimated 5 to 10 t/ac/yr after three
to five years, finally stabilizing at an estimated 1 to
3 t/ac/yr in about two decades. During the past
decade soil productivity has been reduced on
9,279 acres of BLM-administered land (5,276 acres
by harvest and yarding methods that compact the
soil and 3,553 acres bared by road construction
activities). Table 2-3 shows totals within the
Roseburg District.
Fragile soils are found throughout the Roseburg
SYUs. These soils include 33,547 acres of granitic
soils or other soils that have a high potential for
mass-failure and 138,711 acres of soils on very
steep slopes with inclusion of unstable headwalls.
These acres and the percentages of the BLM area
are shown in Table 2-4.
Mass movements tend to occur in draws where the
slopes are steep and the soils are extremely
fragile. Fragile soils are mostly shallow (less than
20 inches to bedrock), have greater than 35
30
percent by volume of coarse fragments (rock and
gravel), occur on slopes of 60 to 80 percent or
greater and have low water-holding capacity and
moderately rapid permeability.
The two major kinds of mass movement of soils in
the Roseburg SYUs are slumps and debris
avalanches. Slumps are one or more blocks of soil
that have rotated out of a hillside along a bowl-
shaped failure plane. Debris avalanches are the
rapid movement of incoherent soil, rocks and
forest debris down steep draws. Soils that are
associated with debris avalanches are usually
those loamy and/or gravelly soils formed over
decomposing granitic bedrock, sandstone, hard
tuffs or breccias on 70 percent or greater slopes.
Debris avalanches occur on the following soils in
the SYUs: Holland and Siskiyou (slopes over 70
percent); Digger, Jason and Umpcoos (over 75
percent slopes); Larmine, Atring, Kilchis,
Harrington, Chamate and Shippa soils (slopes over
80 percent).
Table 2-3 Bared Soils and Road
Surfaces
Failing cut-and-fill slopes and soil
mass-movements 700 acres
Unsurfaced roads causing erosion 600 acres
Road surface 12,000 acres
Totals 13,300 acres
Footnote
Estimates based on district soil scientist field experience and
observations
Water Resources
The SYUs lie within four major river basins.
There are 188,440 acres of BLM-administered land
drained via the South Umpqua River, 65,100 acres
drained via the North Umpqua River, another
154,900 acres are drained by the main stem of the
Umpqua River and 14,560 acres are drained by the
Middle Fork Coquille River. Within these large
watersheds, smaller sub-watersheds have
problems with debris, sedimentation, bank erosion
and elevated temperatures. The rivers and creeks
with severe problems are shown in Table 2-5.
Water quality problems in the SYUs are non-point
source pollution resulting from debris,
sedimentation, bank erosion and elevated
temperatures. High sediment loads and
streambank erosion occur during periods of peak
flow (winter and spring), while problems of
elevated temperatures, low dissolved oxygen and
nuisance algae occur during periods of low flow
(summer). Streamflow data collected at gauging
stations within or nearby the SYUs are given in
Table 2-6, Streamflow Data.
Table 2-7 shows water and sediment discharge
measured at selected gauging stations throughout
the SYUs. The sediment yield ranges from 0.4 tons
per acre at Olalla Creek near Tenmile to 3.0 tons
per acre at the mouth of Lookingglass Creek.
These values represent a long-term average and
may differ greatly from year to year. Peak yields
occur during the period of high runoff.
Sediment losses from the SYUs depend on the
changing combination of many watershed
variables. Within the SYUs, which are mostly
forested, a small portion of the sediment produced
is attributable to purely natural forces. This loss
represents the geologic rate of erosion.
Table 2-4 Fragile and Problem Soils
Problem
Figure 2-2
Color
Acres
Percent
of SYUs
Soils on very steep slopes with inclusion of unstable
headwalls.
Blue
138,711
33
Soils on very steep slopes with inclusion of unstable
headwalls and a high potential for failure when trees are
removed.
Green
4,639
1
Granitic soils with severe surface erosion and inclusion
of unstable headwalls.
Yellow
24,481
6
Granitic soils on very steep slopes with inclusion of
unstable headwall and a high potential for failure when
trees are removed.
Green
4,426
1
Footnote
Due to map scale (Fig. 2-2) it is not possible to delineate individual fragile sites
I
Lookout Poirrr
4-X
WILLAMETTE
iv'T^
>
11
\W
Bu/nl Pea* *
Li
FIGURE 21
PHYSIOGRAPHIC PROVINCES
U. S DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
ROSEBURC DISTRICT
DOUGLAS AND SOUTH UMPQUA
SUSTAINED YIELD UNITS
Roseburg Environmental Impact Statement Area
1982
UDICMESIC SOILS
1 Digger- Jason- Preacher Association
2 Honey grove-Peavine-Preacher Association
3 Honeygrove-Shtvigny Association
4 Klickitat-Harrington Association
FIGURE 2-2
GENERAL SOILS
U. S. DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
ROSEBURG DISTRICT
DOUGLAS AND SOUTH UMPQUA
SUSTAINED YIELD UNITS
Roseburg Environmental Impact Statement Area
1982
35
Table 2-5 Severe Water Quality Problems
Water
Elevated
Withdrawals
Severe
Water
Causing
Sedimen-
Streambank
Temper-
Quality
tation
Erosion
atures
Problems
Cow Creek
X
X
X
North Myrtle Creek
X
X
X
X
South Myrtle Creek
X
X
X
X
South Umpqua River
X
X
X
X
Twelvemile Creek
X
Elk Creek
X
X
X
Smith River (Headwater)
X
X
X
Tenmile Creek
X
X
X
Lookingglass Creek
X
X
X
Olalla "
X
X
X
Middle Fork Coquille River
X
X
Sutherlin Creek
X
X
Rock Creek
X
X
X
Canton Creek
X
X
Canyon Creek
X
X
X
Days Creek
X
X
X
Little River
X
X
Source: ODEQ Aug. 1978
Groundwater supplies are highly variable and
limited. Most wells produce only enough water to
supply single households, and some may go dry
during the summer. In the Drain-Yoncalla area,
water supply is very poor. In the Willis and Rice
Creek Drainages, groundwater supply is almost
non-existent. Cow Creek has one of the better
groundwater supplies in the county. Winston,
Dillard, Tenmile, Elkton and Olalla have fair
supplies.
Heavy irrigation withdrawals are taken from Elk
Creek, Calapooya Creek and the Umpqua River
and throughout the South Umpqua River system.
Bear Creek and Adams Creek watersheds, located
near Drain and Yoncalla, are used as sources for
domestic water supply by these two communities.
In addition, several communities withdraw water
for domestic use. The Roberts Creek Water District
has rights on the South Umpqua River, the South
Umpqua Water Association has rights on Cow
Creek and serves 40 percent of Canyonville and
the area between Riddle and Canyonville. The
remainder of Canyonville uses O'Shea Creek and
West Fork of Canyon Creek. Myrtle Creek uses the
South Umpqua River as a backup source, and the
Tri-City Water Association has rights on the South
Umpqua. Riddle uses Judd, Cow and Russell
Creek watersheds for municipal water supplies.
Vegetation
The SYUs are located in the Northwest
Coastal Coniferous Sub-biome, which is the most
densely forested region in the Coniferous Biome.
Characterized by easy regeneration and rapid
growth, it produces trees of impressive sizes. The
lower vegetative layers are usually poorly
developed except where open canopies encourage
a lush understory of grasses, shrubs and
herbaceous species. Additional information may
be found in the BLM Timber Management FEIS.
Terrestrial Vegetation
For purposes of this EIS, vegetation is
generally described in terms of "zones" adapted
from those identified by Franklin and Dyrness in
Natural Vegetation of Oregon and Washington
(1973). A detailed description of each zone and
plant community listed below may be found in that
source or from data prepared in the Roseburg
District. A complete list of common and scientific
names for all plants discussed is available upon
request.
Portions of three major vegetative zones, Mixed
Conifer, Western Hemlock and Interior Valley, are
found within the SYUs.
The southern portion of the SYUs above 1,000 feet
in elevation is generally occupied by the Mixed
Conifer Zone. Approximately 50 percent of BLM-
administered lands in the SYUs lie within one of
the following three major plant communities.
36
Table 2-6 Streamflow Data
Location
Average Discharge/Yr
(CFS) (Ac. Ft.)
Peak
(CFS)
Discharge
(Date)
Minimum
(CFS)
Discharge
(Date)
Cow Creek
(Riddle)
898
650,600
41,100
Oct. 1950
7.4
Aug. 1977
Olalla Creek
(Tenmile)
94.2
68,200
12.300
Dec. 1955
several yrs.
Tenmile Cr.
(Tenmile)
64.4
46,700
3,650
Jan. 1971
several yrs.
Lookingglass
Cr. (Brockway)
287
207,900
35.000
Dec. 1955
several yrs.
Steamboat Cr.
(below Canton
Cr.)
741
536,900
51,000
Dec. 1964
30
Sept. 1973
Rock Cr. (above
fish hatchery)
373
270,200
22,800
Dec. 1964
14
Sept. 1966
Little River
(Peel)
475
344,100
22,700
Nov. 1953
14
several yrs.
N. Umpqua R.
(Winchester)
3,746
2,714,000
150,000
Dec. 1964
383
Sept. 1960
Calapooya Cr.
(Oakland)
485
351,300
26,600
Nov. 1961
1966, 1974
Umpqua River
(Elkton)
7,504
5,437,000
265.000
Dec. 1964
640
July 1926
Elk Creek
(Drain)
227
164,400
15,000
Feb. 1961
several yrs.
Smith River
(Gardiner)
976
547,700
26,000
Feb. 1961
4.3
Aug. 1966
S. Umpqua R.
(Tiller)
1,042
754,900
60,200
Dec. 1964
20
Sept. 1911
Elk Creek
(Drew)
85.6
62,020
8,880
Dec. 1964
1974, 1977
Days Creek
(Days Creek)
44.4
32,170
3,450
Feb. 1956
Jl/Ag 1961
S. Myrtle Cr.
(Myrtle Cr.)
65.9
57,740
3,050
Dec. 1956
0.2
Aug. 1961
N. Myrtle Cr.
(Myrtle Cr.)
74.2
53,760
3,260
Jan. 1964
1973, 1977
S. Umpqua R.
(Brockway)
2,899
2,100,000
125,000
Dec. 1964
16
Aug. 1977
Source: USDI. BLM Roseburg
District URA 1980a (as of 1978 water year)
37
Table 2-7 Sediment Discharge Data
Location
Mean Annual
Suspended Sediment Discharge
Maximum
Observed
Discharge
(Tons/Year)
Concentration
(Mg/L)
Yield
(Tons/ Ac)
Concentration
(Mg/L)
Discharge
(Tons/Day)
Steamboat Cr.
(below Canton Cr.)
210,000
240
1.2
3,870
106,000
N.Umpqua R.
(Winchester)
800,000
120
1.0
768
71,200
Umpqua River
(Elkton)
3,500,000
370
1.5
927
196,000
Elk Creek
(Drain)
74,000
230
1.1
2,930
9,730
Olalla Creek
(Tenmile)
16,000
150
0.4
3,600
3,040
Lookingglass
Cr. (Brockway)
310,000
890
3.0
2,600
35,100
S. Umpqua R.
(Brockway)
1,700,000
500
1.6
1,800
208,000
S. Umpqua R.
(Tiller)
140,000
120
0.5
1,260
65.100
Cow Creek
(Riddle)
370,000
370
1.3
1,360
64,600
Source: USDI, BLM 1980a.
a. White fir, western hemlock, vine maple, western
yew
b. White fir, Douglas-fir, Whipple vine
c. Douglas-fir, incense cedar, pine-mat manzanita.
Frequent associates to these plant communities
which are also important to the forest industry
include sugar pine, ponderosa pine, western
redcedar and western white pine.
The Western Hemlock Zone extending throughout
the northern portion of the SYUs at all elevations,
covers approximately 47 percent of BLM-
administered lands in the EIS area. It is famous for
its subclimax species, Douglas-fir, which is often
the sole dominant tree in the forest. As a pioneer
species, Douglas-fir normally constitutes a serai
(successional) stage during the vegetative
community development process. This zone
encompasses six major plant communities with
various associations of trees, shrubs and forbs
relative to specific climatic conditions such as
aspect, moisture, soil type and depth, etc. These
communities are listed on a site moisture gradient
from dry to wet:
a. Douglas-fir, ocean spray
b. Western hemlock, golden chinkapin
c. Western hemlock, Pacific rhododendron, salal
d. Western hemlock, Pacific rhododendron,
Oregon grape
e. Western hemlock, swordfern, Oregon oxalis
f. Western redcedar, western maidenhair fern,
ladyfern
The Interior Valley Zone includes the lowlands and
valley bottoms enclosed by the Cascade'and Coast
Ranges. Approximately 3 percent of BLM-
administered lands occur within this zone at
elevations up to 1,300 feet. Plant communities vary
from grasslands and oak-madrone woodlands in
low areas to conifer forests on the slopes.
Frequent associates to these plant communities
are Douglas-fir, ponderosa pine, incense cedar,
ocean spray, Oregon grape and rye grasses.
Riparian habitat occupies the transitional
terrestrial areas from the water's edge to the
better-drained slopes. Vegetation in these areas
ranges from a few aquatic species and the
hardwood-western redcedar-hemlock type, to the
predominant Douglas-fir stand usually found on
the slopes.
38
Habitat stratification for all forested land of the
entire Roseburg Area is depicted in Table 2-8. The
entire Roseburg Area includes all lands in Douglas
County east of the crest of the coast range.
Acreages listed are a composite of all ownerships
obtained from several sources (USFS; OSDF;
OSDT) as well as the BLM forest inventory. The
acreages of BLM-administered lands are shown for
comparison.
Table 2-8 Existing Forest Habitat
Stratification of Entire Roseburg
Area (Acres)
Habitat Age
BLM
All Lands
Grass/Forb
(non-stocked and
0-7 years)
34,100
213,900
Brush/Seedling
(8-15 years)
40,900
239,100
Pole/Sapling
(16-45 years)
56,400
356,800
Young 2nd Growth
(46-115 years)
82,200
258,900
Mature
(116-195 years)
79,800
121,500
Old Growth
(196+ years)
110,900
234,100
Source: USDI. BLM; USDA, FS; Oregon State Department of
Forestry; Oregon State Department of Transportation (Parks and
Recreation Branch)
The old-growth forests existing today are complex
ecosystems which have evolved by natural
selection through successional stages during the
vegetative community development process.
Evidence now points to the simultaneous evolution
of mycorrhizal tree hosts, hypogeous fungi, and
small mammals that function as a transport
mechanism for the fungi.
Research required to fully understand the
relationships and importance of these processes to
long-range timber production has not yet been
completed. It now appears that dispersal of
mycorrhizal fungi by small mammals may be a
critical factor in forest plantation establishment
and survival in some instances (Maser et al. 1978).
The functioning of the old growth forest as a
system, however, has not yet been studied in
depth. As recently as 10 years ago, nothing was
known about sources of nitrogen in old growth
stands. It is now known that lichens which inhabit
the canopy of live old growth trees fix significant
amounts of nitrogen which ultimately become
available to the whole forest through leaching,
litter fall and decomposition. Also, lichens and
wood-dwelling bacteria on standing dead trees
and logs have recently been identified as
significant sites of nitrogen fixation (Franklin et al.
1981).
Seed zones are accepted as generally
encompassing a geographic area within which the
factors affecting reforestation and subsequent
growth are relatively homogeneous (Appendix A).
Seed zones and elevational intervals involving
BLM-administered lands in the Roseburg SYUs are
shown in Table A-1.
Wetland and Aquatic
Vegetation
Wetlands are those areas inundated by
surface or ground water at a frequency sufficient
to produce a saturated or seasonally saturated soil
condition. Examples of wetlands include marshes,
swamps, bogs, wet meadows and natural ponds.
Sedges, grasses, rushes, skunk cabbage, cattails
and algae are typical wetland and aquatic plants.
Sensitive, Threatened and
Endangered Plants
Endangered plants are those species that are
in danger of extinction throughout all or a
significant portion of their range. Threatened plant
species are those that presently are not
endangered but are likely to become so within the
foreseeable future throughout all or a significant
portion of their range. Sensitive plants are those
species not yet officially listed but undergoing a
status review (see Glossary-Sensitive Species).
Botanical surveys for sensitive, threatened and
endangered plants were conducted on the
Roseburg District from 1978 through 1980 and are
continuing. At present, one federally listed
endangered plant (Arabis macdonaldiana,
McDonald's arabis) is suspected to occur in the
EIS area, but as yet remains unobserved. Several
species observed in the EIS area are currently
under review for listing as threatened or
endangered by the U.S. Fish and Wildlife Service
(Table 2-9). The final status of these species will
be determined as sufficient data are collected.
39
Table 2-9 Sensitive Species Currently Under Review For Possible Listing
Candidate
Observa-
Scientific Name
Common Name
for 1
tions 2
Arabis koehleri
shrubby rockcress
E
B
var. koehleri
Aster vialis
wayside aster
E
C
Calochortus greenei
Green's mariposa-lily
T
B
Calochortus howellii
Howell's mariposa-lily
T
B
Camassia leichtlinii
great camas
A
var. leichtlinii
Cypripedium californicum
California lady's slipper
T
B
Cypripedium montanum
mountain lady's slipper
T
A
Darlingtonia californica
California pitcherplant
T
C
Dicentra formosa
Oregon dicentra
E
C
(spp. oregana)
Frasera umpquaensis
Umpqua swertia
T
C
Kalmiopsis leachiana
kalmiopsis
C
Lathyrus holochlorus
thin-leaved peavine
T
B
Lewisia cotyledon
imperial lewisia
T
B
var. howellii
Limnanthes gracilis
slender meadow-foam
T
B
var. gracilis
Mimulus pygmaeus
pygmy monkey flower
C
Perideridia erythrorhiza
false caraway
T
B
Phacelia capitata
scorpion weed
T
A,B
Phacelia verna
Umpqua phacelia
T
A,B
Plagiobothrys hirtus
rough allocarya
C
fspp. hirtus)
Romanzoffia thompsonii
romanzoffia
T
A
Sidalcea cusickii
Cusick's checker-mallow
T
B
Synthyris missurica
Howell's grouse flower
C
(spp. hirsuta)
Thlaspi montanum
pennycress
T
A,B
var. siskiyouensis
Viola lanceolata
western bog violet
T
C
var. occidentalis
' Threatened (T). endangered (E), undesignated to date (blank). All species are designated as
Bureau Sensitive Species by the Oregon State
Director
■ Observed; on BLM-A. on other lands in the SYUs - B, Unobserved - C.
Animals
Terrestrial Animals
Animal distribution, diversity and abundance
are dependent on various factors: of primary
importance is vegetation. Each vegetational zone
described in the previous section contains a
variety of plant communities which may be in
different successional stages. Each successional
stage has a unique structure, and it is primarily
this structure to which animal communities
respond. The differences in communities,
successional stages and structure provide habitat
diversity and account for the variety of animals
found in the planning area.
Successional stages are dynamic. They are always
progressing toward their climax form, and during
this progression their animal components are also
changing. Progress toward climax can be curtailed
at any point by outside influences, either natural or
artificial. For instance, fire or logging may set back
succession, and those animal species associated
with the current stage will be replaced with those
adapted to exist in the early successional stages.
Modifying or removing one particular stage, e.g.,
old growth, has a significant effect on those
individuals and species occurring there. It is
recognized that these effects do not stop with just
those species, as the ecosystem as a whole is
altered by the modification of one of its parts.
Certain results may be harmful to some species
and beneficial to others, but all are affected.
40
There are 32 species of amphibians and reptiles,
184 species of birds and 70 species of mammals
that occur or probably occur in the planning area.
Some species of animals are quite restricted in
their habitat requirements, while others have a
wide tolerance. For instance, the robin occurs in
most habitat types while the northern spotted owl
is much more restricted.
Appendix D lists those species of terrestrial
vertebrates occurring in the planning area, some
information on their habitat requirements and what
is known of the status of their population and
habitat.
From the perspective of all ownerships, the
progression toward climax on intensively managed
lands in the SYUs has been halted and reverted to
early successional stages by planned timber
management activities. In 1930, for example, most
of the forest land acreage supported mature and
old growth stands. The most recent inventories
(Appendices E and F) show (Table 2-8) a greater
diversity than that which existed under more
"natural" conditions 50 years ago.
The present diversity, however, is a transitory
condition. The forest management activities that
created the current diversity on the commercial
forest land base will, if carried to the planned
conclusion, result in a situation where the oldest
forest stands will be 80 years of age. Since
approximately 71 percent of the area is not
controlled by the BLM, this is the situation that is
most likely to occur on most of the area.
Habitat structure for all lands within the SYUs
regardless of ownership or administration cannot
be accurately calculated. However, based on data
from a variety of sources, habitat structure for the
entire area was estimated for all forest lands and is
shown in Table 2-10. The "all lands" category
consists of forest lands within Douglas County
east of the crest of the Coast Range. Total land
area is approximately 1.4 million acres. Bureau
forest lands in the table approximate 404,000
acres.
Old-growth forests provide optimum habitat for a
variety of animal species (see Appendix D) and are
important to the entire forest ecosystem (Franklin
etal. 1981). Old-growth habitat totals 110,900
acres or 27 percent of Bureau-managed forest
lands in the SYUs (Tables 2-8 and 2-10).
Other types of habitat exist and can be modified
by forest management practices. Of special
concern are snags. Snags provide optimum habitat
for 33 species and are used to some extent by 47
other species of birds and mammals in the SYUs
(see Appendix D). That cavity-nesting birds feed
on insects and play an important part in control of
forest insect pests has been well reviewed by
Thomas (1979).
Table 2-10 Habitat Structure of Forest Lands
in
the SYUs (by percent)
BLM Habitat
Habitat Age
All Forest
Lands
BLM
as a
Percent of All
Forest Lands*
Grass/Forb
(non-stocked and 0-7
years)
15
9
16
Brush/Seedling
(8-15 years)
17
10
17
Pole/Sapling
(16-45 years)
25
14
16
Young 2nd Growth
(46-115 years)
18
20
32
Mature
(116-195 years)
9
20
66
Old Growth
(196+ years)
16
27
47
" This column indicates, for example, that while 27 percent of BLM land is old growth, this is 47 percent of all
old growth in the defined area
Source: USDI, BLM. USOA. FS
; Oregon Department of Forestry;
Oregon Division of Parks and Recreation
41
Under natural conditions, snags occur throughout
the forest as a result of fire, disease and other
factors. Timber harvest practices generally result
in their removal for safety and fire prevention.
Recent snag surveys by district personnel revealed
an average of 0.1 snags per acre in coniferous
forests less than 15 years of age under BLM
administration. Due to the large amount of older
forest lands, snag densities are currently at high
levels, although distribution is not even.
Riparian zones are an extremely important habitat
because they are used to a greater extent by a
greater variety of species than any other habitat.
Of the 286 species of terrestrial vertebrates found
in the planning area, 82 find their optimum habitat
in riparian zones while another 170 species use
this habitat for part of their overall needs (see
Appendix D).
In western Oregon riparian zones vary in width;
generally, the larger the stream the wider the
riparian zone. Vegetation within these areas
includes plants only found in association with
water as well as others including hardwoods and
merchantable softwoods.
Currently, there are about 22,800 acres of riparian
habitat on BLM-administered lands in the SYUs
(USDI, BLM 1980a). Approximately 12,150 of these
acres are along small first and second order
streams. Because of the intermittent nature of
these streams, the riparian habitat is not as well
developed as on larger rivers and is more nearly
like the adjacent upland habitat.
The riparian habitat on third order and larger
streams represents about 3 percent of the forest
land base. Some of this has been altered by past
timber management practices and is in less than
optimum condition.
Elk are not evenly distributed. While limited
numbers in scattered herds do occur in the other
areas, elk are concentrated in the Tyee area, which
includes Powell, Basin, Wolf, Cougar and Hubbard
Creek drainages. Habitat on BLM lands in this area
is currently in the following condition:
Forage Area
Hiding and Escape
Cover
Thermal Cover
Survival Cover
0-15 years
16-45 years
46-120 years
120* years
15%
17%
12%
56%
* Survival cover can be substituted for thermal cover but thermal cover
can not be substituted for survival cover
Source USDI, BLM 1980a and district personnel.
The mature and old growth components are
important to elk if optimum or near optimum
populations are to occur. In times of extreme
temperatures they function as survival cover,
providing forage, temperature moderation and
snow interception (Jenkins and Starkey 1980, De
Calesta and Witmer 1980, Smithey et al. 1982).
Much of the adjacent land under other ownership
has been cut over and provides forage and escape
cover. It is primarily Bureau-managed lands that
supply the thermal cover component.
Fish
Salmonids are the most important group of
fish found in the SYUs. Other native species such
as sculpins, suckers, dace and squawfish are also
present within the area.
Introduced species such as brown bullhead,
smallmouth bass, largemouth bass and shad are
also present and becoming an important fishery.
With the exception of information concerning
salmonids in the North Umpqua River, there is
little population data available. There is even less
available when limited to BLM land. It can be
assumed that current habitat conditions and fish
populations reflect past land management actions
and fish harvest regulations. In the case of
anadromous fish, the ocean habitat becomes a
third component influencing population levels.
Timber management on all lands has been the
most significant land management action.
Changes in timber management practices
beginning in the 1960's and natural
reestablishment of streamside vegetation on lands
logged earlier have resulted in an improvement to
stream fish habitat.
To some extent, all salmonids have the same or
similar habitat requirements such as temperature,
dissolved oxygen, spawning habitat and food
supplies. Although there are strong similarities in
some streams, there are highly varied population
levels when one species is compared to another
(see Table 2-11).
The North Umpqua Resource Area is rated as
good spring cninook habitat and fair fall Chinook
habitat. Both races have similar habitat
requirements but the North Umpqua has never
supported comparable populations. Similar
comparisons can be made between summer and
winter steelhead or steelhead and coho salmon.
Recognizing these and other differences, Table 2-
11 was prepared showing information by BLM
Resource Area. Examples of streams in each
resource area are as follows:
Drain Resource Area: Smith River and Wolf
Creek
North Umpqua Resource Area: North Umpqua
and Little River
South Umpqua Resource Area: Myrtle Creek and
Days Creek
Dillard Resource Area: Cow Creek and 12 Mile
Creek
42
Table 2-11 Salmonid Fish Habitat and Populations
Drain Resource Area
Miles of Habitat (BLM)
Miles of Habitat (other ownership)
Habitat Quality
Wild Fish Population Trend
Hatchery Supplement
North Umpqua Resource Area
Miles of Habitat (BLM)
Miles of Habitat (other ownership)
Habitat Quality
Wild Fish Population Trend
Hatchery Supplement
South Umpqua Resource Area
Miles of Habitat (BLM)
Miles of Habitat (other ownership)
Habitat Quality
Wild Fish Population Trend
Hatchery Supplement
Dillard Resource Area
Miles of Habitat (BLM)
Miles of Habitat (other ownership)
Habitat Quality
Wild Fish Population Trend
Hatchery Supplement
Key
E = Excellent
G = Good
Spring
Fall
Chinook
Chinook
Cohc
9
20
79
46
66
255
1
F
P
'
S
D
No
No
2
8
8
18
71
71
105
G
F
P
S
S
D
40%'
No
2
2
26
46
46
142
P
P
P
D
I
D
No
No
No
6
24
—
44
147
—
P
I
P
D
—
No
No
F = Fair
P = Poor
S = Stable
I = Increase
D = Decrease
1 Only present during passage to and from the ocean.
2 Release of hatchery reared smolts initiated but too soon for adult returns.
3 Percentage of total adult run attributable to hatchery reared smolts.
" Percentage of trout harvest attributable to hatchery reared legal sized fish.
Source: USDI, BLM 1980a, and BLM district personnel.
Winter
Summer
Steel-
Steel-
Sea-run
Resident
head
head
Cutthroat
Trout
79
9
79
108
255
46
255
297
F
P
F
S
'
D
D
No
No
No
No
34
28
34
57
154
45
154
275
F
G
P
F
S
S-l
D
S
No
50%'
No
95%'
26
26
57
142
—
142
214
P
—
P
F
S-l
—
D
S-D
50%
—
No
95% 4
24
24
48
147
—
147
162
F
—
P
F
S-l
—
D
D
50%
—
No
No
Table 2-12 Threatened and
Endangered Species of the
Roseburg SYUs
Federal
Oregon
Species
Status
Status
Northern bald eagle
T
T
Haliaeetus
leucocephalus
alascanus
Northern spotted owl
T
Strix occidentalis
caurina
Columbian white-tailed deer
E
E
Odocoileus virginianus
leucurus
T = Threatened
E Endangered
Threatened and Endangered
Animals
There are three species of animals
officially listed by the U.S. Fish and Wildlife
Service and/or the State of Oregon as threatened
or endangered that occur at least occasionally in
the SYUs. Table 2-12 lists those species and their
status.
The bald eagle is a regular inhabitant of the SYUs
and there are two pairs known to nest on BLM-
administered land.
The northern spotted owl is a permanent resident
of the SYUs. On Bureau-administered lands, there
are 55 habitat units, each known to support one
pair of owls. An additional 30 locations have been
identified as occasionally containing owls. These
may be juveniles or single birds. Inconsistent
sighting and the quality of the habitat make it
unlikely these areas are capable of supporting
breeding pairs.
43
The 55 habitat units were judged to be in the
following condition:
Poor 4 Very Good 1 1
Fair 12 Excellent 9
Good 19
The criteria used to judge the conditions were:
Poor = <1 50 acres old growth
1,050 acres <80 years
Fair = <300 acres old growth
900 acres <120 years
Good = 300+ acres old growth
450 acres 30-200 years
450 acres <30 years
Very Good = 500+ acres old growth
200 acres 120-200 years
200 acres 30-120 years
300 acres <30 years
Excellent = 700+ acres old growth
200 acres 120-200 years
100 acres 30-1 20 years
200 acres <30 years
In the opinion of the BLM district biologist, those
units in the poor habitat category are extremely
marginal and will eventually fail to support owls.
An additional 63 pairs of owls have been recorded
on lands of other ownership within the planning
area, primarily on lands administered by the U.S.
Forest Service.
The Columbian white-tailed deer is a resident of
the oak-ash bottom lands and the oak-madrone
uplands and is found on Bureau-managed lands,
but predominantly on lands in other ownerships.
The U.S. Fish and Wildlife Service has not
designated any critical habitat under Section 4 of
the Endangered Species Act within the SYUs.
However, BLM identified essential habitat totaling
37 acres for the Columbian white-tailed deer and
3,475 acres for the bald eagle was delineated in the
SYUs and recommended to the U.S. Fish and
Wildlife Service for further consideration.
Recreation
Developed recreation sites on public land include
Gunter, Tyee, Lone Rock, Mill Pond, Rock Creek,
Scaredman, Susan Creek Recreation Area, Cavitt
Creek, Wolf Creek Trail and Emile (see Figure 1-1).
Each site (except trails) has facilities for overnight
camping and/or picnicking. Annual use at the 10
developed sites is approximately 19,000 visitor
days, with about 43 percent attributable to
overnight use. Opportunities are also available for
dispersed camping and picnicking throughout the
SYUs.
Fishing for anadromous species is a major
recreational activity in the SYUs. Some fishing for
trout and warm water game fish also occurs. Most
stream fishing use is in the Umpqua (Main, North
and South), Smith and Little Rivers, Rock Creek
and Cow Creek. The North Umpqua River is
nationally known for its anadromous fishery.
The major hunting activity on public land is for
deer and elk. Hunter success is affected by game
populations, ease of movement and shooting
opportunities. Hunting with hounds for bear and
cougar also occurs throughout the SYUs.
Most general sightseeing use occurs in association
with travel along major roads. Some people also
visit public lands with specific sightseeing goals or
may include sightseeing as a part of other
activities. Examples of such areas with
opportunities for this use include the North
Umpqua River Highway, Cavitt Creek Falls, Maude
"S" Mine, Susan Creek Indian Mounds, Main and
South Umpqua River, Susan Creek Falls, Wolf
Creek Falls and a number of scenic overlooks.
High quality opportunities are available for
swimming, canoeing, kayaking and floatboating.
Most use occurs on the Umpqua River (Main,
North and South Forks) and Cow Creek. Off-road
vehicle (ORV) use in the SYUs is generally limited
to existing roads and trails. In recent years this
recreational use has increased rapidly. Although
use is low, opportunities are available for areawide
berry picking and horseback riding, goldpanning
and rock collecting.
The Nationwide Rivers Inventory prepared by the
Heritage Conservation and Recreation Service
(HCRS) and National Park Service (NPS) has
identified sections of the Umpqua and North
Umpqua as potential national wild, scenic or
recreational rivers crossing public land within the
SYUs (USDI, HCRS 1980). The North Umpqua
River has also been identified by the State of
Oregon for potential State Scenic Waterway
designation. The State Transportation
Commission reviewed the study but chose not to
continue the designation process for the North
Umpqua River (Lilly 1981).
Table 2-13 summarizes visitation attributable to
major recreation activities in the SYUs.
Recreational demand projections to 1990 are also
displayed.
Cultural Resources
BLM is required by law and executive order
to identify, protect and enhance significant
cultural resources on public lands. A number of
procedures, including those specified in 36 CFR
800.4(a), were used to identify the cultural
resources within the SYUs.
44
Table 2-13 Estimated Current and Projected Visitation Attributed to Major
Recreation Activities
Activity
Current Visitation 1
Visitor Days/Year
1990 Demand Projection 2
Visitor Days/Year
Total 3
(Douglas
County)
BLM
(Roseburg
District)
Total 3
(Douglas
County)
BLM
(Roseburg
District)
Hunting
Big game
Upland game
194,060
35,120
23,250
2,510
204,630
37,330
24,460
2,670
Fishing
All anadromous
Resident cold-water
Resident warm-water
124,000
103,800
5,200
23,670
19,190
490
186,000
129,750
10,400
35,510
23,990
980
Camping
Hiking
Horseback riding
Hound sports
ORV use
Other day use 4
Total
796,300
23,560
25,390
182,330
500,330
598,670
2,588,760
8,220
420
460
3,280
9,010
10,780
101,280
978,000
28,940
31,180
223,930
614,500
735,270
3,184,930
10,100
520
560
4,030
11,070
13,240
127,130
1 Based on data collected between 1976-1978
: Based upon projections in USDI, BLM (1980b), conversations with Oregon Department of Fish
Transportation (1978)
1 Total visitation includes use in the coastal region where public lands are limited.
* Total area day use visitation excludes urban and semi-urban activities not generally associated
and Wildlife staff and Oregon Department of
with forest lands administered by BLM
Source: USDI. BLM 1980b.
A survey of existing cultural resource information
(Class I survey) has been completed for the SYUs
(Honey and Hogg 1980) through a compilation of
the area's existing site record data. A thorough
survey to locate and identify cultural resources is
accomplished prior to ground disturbance or
ownership changes. The results of this intensive
survey are documented in each site specific
environmental assessment.
The criteria used to assess the eligibility of
identified cultural resources for inclusion in the
National Register of Historic Places are described
in36CFR 1202.6.
Prehistoric Sites
While little of the area has been field
surveyed for prehistoric resources due to its steep,
heavily forested terrain, there are 90 recorded
prehistoric sites on or near public land within the
SYUs (Honey and Hogg 1980). Most are trailside
and/or hunting camps associated with Indian use
of upland resources. An area's available resources
such as water, plant and animal foods, workable
stone, or amenable terrain probably determined
the nature and location of sites.
Examples of areas within the SYUs which exhibit a
relatively high density of prehistoric sites include
Upper Little River, Susan Creek vicinity, Upper
Middle Creek, Camas Valley-Boulder Creek and
the White Rock-Dompier Creek Region.
A group of rock mounds in the Susan Creek
vicinity is currently listed on the National Register
of Historic Places (see Glossary).
Historic Sites
There are 41 inventoried historic sites on
or near BLM-administered land within the SYUs
(Honey and Hogg 1980). About 80 percent of the
sites have not been formally recorded and are in
need of further documentation. Most historic sites
in the SYUs relate to fur trade, settlement,
transportation, mining and logging. None of the
historic sites on public land is currently listed on
the National Register of Historic Places.
Paleontologic Sites
No important or scientifically unique
paleontologic sites have been identified in the
SYUs. However, all reports of fossil-bearing
deposits are examined by qualified personnel to
avoid destruction of such resources.
45
Visual Resources
Visual resources are the land, water,
vegetation, animals and the other features (as
described in this chapter) that are visible on public
lands. Visual resource management (VRM)
objectives have been developed based on three
factors (BLM Manual 8400). These factors are
scenic quality, visual sensitivity and distance zone
(see Glossary). Examples of high to moderate
scenic quality and visually sensitive areas on
public land include Coles Valley, Umpqua River,
Berry Creek Reservoir, Bushnell Rock, Susan
Creek Falls, North Umpqua River, Cooper Creek
Reservoir and portions of the viewshed from
Interstate 5.
VRM classes specify management objectives and
allow for differing degrees of modification.
Objectives for each VRM class follow:
Class I: Provides primarily for natural ecological
change (highest levels of protection). Generally
includes highly scenic and/or highly sensitive
areas.
Class II: Changes in any of the visual resource
basic elements (see Glossary) caused by a
management activity should not be evident in the
characteristic landscape. A change may be seen
but should not attract attention (retention of
scenic quality). Generally includes areas with high
to moderate scenic quality and/or sensitivity.
Class III: Changes in the basic elements caused by
a management activity may be evident in, but
should remain subordinate to, the existing
characteristic landscape (partial retention of
scenic quality). Generally includes moderate
scenic quality and/or sensitivity.
Class IV: Changes may attract attention and be
dominant landscape features but should reflect
those basic elements inherent in the characteristic
landscape (modification of scenic quality - lowest
level of protection). Generally includes areas with
moderate to low scenic quality that are seldom
seen.
Figure 2-3 shows VRM classes as recommended
through the visual resource inventory and
evaluation of the existing environment.
Wilderness Values
Under the terms of the Federal Land Policy
and Management Act of 1976 (FLPMA), roadless
areas of 5,000 acres or more that have wilderness
characteristics are to be reviewed within 15 years
for possible wilderness designation. The 1976 Act
also states that in the event of inconsistency
between it and the O&C Act insofar as they both
may relate to management of timber resources, the
O&C Act prevails. Accordingly, the wilderness
review provisions do not apply to revested Oregon
and California Railroad grant lands suitable for
sustained yield management as commercial timber
lands.
No areas within the SYUs are proposed wilderness
study areas. The intensive wilderness inventory
and accompanying maps for Oregon and
Washington are available in the Oregon State
Office.
Areas of Critical
Environmental Concern
Areas of Critical Environmental Concern
(ACECs) are areas within the public lands where
special management attention is required to
protect and prevent irreparable damage to
important historic, cultural, or scenic values, fish
and wildlife resources, or other natural systems or
processes, or to protect life and safety from
natural hazards (FLPMA Section 103(a)).
Designation of an area as an ACEC does not
necessarily preclude development but rather
ensures the protection of sensitive values in those
cases where appropriate development may take
place. Following designation, activity plans are
prepared to translate special management
requirements for each area into on-the-ground
implementation actions.
Of the 15 areas nominated for ACEC consideration
during the Roseburg District's planning process
(see Table 2-14), seven were found to be qualified
for ACEC designation. The decision to designate
any or all of these areas as ACECs will be part of
the Management Framework Plan decision for the
SYUs, to be made following completion of this EIS.
Special Areas
The 28-acre Myrtle Island timber
preservation area (see Glossary) was established
in 1951 by Public Land Order Number 754 to
preserve an old growth stand of Oregon myrtle.
This Umpqua River island also has scattered old
growth Douglas-fir (Franklin et al. 1972). Further,
the area is a designated Research Natural Area
(see Glossary). Myrtle Island has also been
identified by the National Park Service (NPS) as a
potential National Natural Landmark (Chilcoteet
al. 1976). Designation of a site as a National
Natural Landmark (see Glossary), a program
administered by the NPS, is not a land withdrawal
and would not affect BLM jurisdiction to manage
the area.
Beatty Creek is a designated Research Natural
Area (RNA). This 173-acre area has a
representation of Jeffrey pine on serpentine soil in
the Siskiyou Mountains physiographic province.
46
Table 2-1 4 Nominated and Potential Areas of Critical Environmental Concern
Approximate
Site Name Size (acres) Description
QUALIFIED FOR ACEC DESIGNATION 1
Primary
Resource Values
Remarks
1 Brad's Creek
137
2. Golden Bar
217
3. North Umpqua River
1,620
4. Tater Hill
169
5. Myrtle Island
28
6. Beatty Creek
7. North Myrtle Creek
(Slideover)
Old growth forest, bald eagle habitat
Old growth forest, bald eagle habitat,
cultural resources
Anadromous fishery, high scenic value
Large, active landslide
28 Old growth Oregon myrtle and Douglas-fir
173 Pure stand of Jeffrey Pine and a grass
community on serpentine soils at low
elevation
480 Coniferous forest mixture in the Umpqua
River Valley
Wildlife, Scenic
Wildlife, Scenic
Wildlife, Scenic
Geologic Proposed
Research Natural
Area (RNA)
Botanic, Scenic Currently
designated RNA
and timber
preservation area
Botanic Designated RNA
Botanic
Proposed RNA
(240 acres)
NOMINATED BUT NOT QUALIFIED FOR ACEC DESIGNATION 2
1 Whistler's Woodlands
22
2. Bluff Creek Bluffs
120
3. Rice-Bushnell Divide
40
4. Canyon Mountain
80
5. North Myrtle Creek
Watershed
13,100
6 Wood Creek
360
7. Dompier Creek
240
Oak woodlands, Columbian white-tailed Wildlife
deer habitat
Candidate threatened or endangered plant Botanic
Candidate threatened or endangered plant Botanic
Candidate threatened or endangered Botanic
plants
Large, geologically complex basin Natural Hazard
Old growth timber, spotted owl habitat Wildlife
Several landslides, slump ponds Geologic Hazard
' Two identification criteria (relevance and importance) derived from the Federal Land Policy and Management Act (1976) were
applied to evaluate all areas nominated for ACEC designation. While Myrtle Island, Beatty Creek and North Myrtle Creek met these
criteria, other measures would be adequate to protect the significant resource values in these areas. Myrtle Island and Beatty Creek
are currently designated Research Natural Areas. North Myrtle Creek is a proposed Research Natural Area.
2 Areas failed to meet the criteria of importance, as described in the August, 1980 Final Guidelines for Areas of Critical Environmental
Concern (USDI. BLM 1980d).
Other areas with potential for RNA designation
include Woodruff Canyon lands, Old Fairview,
Tater Hill and North Myrtle Creek. The Little River
Arch has potential for Outstanding Natural Area
(see Glossary) designation. Red Pond is a
proposed environmental education area.
The BLM currently has five environmental
education use permits on public land. These
permits provide for environmental education and
study of public land resources but do not involve
special designation or facility development.
Socioeconomic Conditions
During 1975 through 1977 logs from the
Roseburg District were trucked to destinations in
Douglas (89.9 percent), Lane (7.3 percent), Coos
(1.9 percent), Josephine (0.1 percent) and Jackson
counties (0.8 percent). These five counties taken
FIGURE 2-3
VISUAL RESOURCE
MANAGEMENT CLASSES
U. S. DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
ROSEBURC DISTRICT
DOUGLAS AND SOUTH UMPQUA
SUSTAINED YIELD UNITS
Roseburg Environmental Impact Statement Area
1982
49
together are evaluated here as the regional
economy affected by the action.
The region is divided by the Coast Range into an
eastern section with a larger and more dispersed
population in the Willamette, Umpqua and Rogue
River Valleys and a western section with a smaller
population concentrated near Coos Bay and in the
Coquille River Valley.
The average level and recent changes in
population, employment, personal income and
public revenue within the regional economy are
the quantitative indicators of social well-being
discussed below. Although this is not a complete
list, these four indicators were selected because
other indicators tend to move consistently up or
down with them and these data have been
tabulated similarly for a number of years.
As shown in Table 2-15, the population of the
region has increased more than 30 percent over
the last decade and now exceeds 600,000. While
paralleling a nationwide shift of population
westward, the rate of growth in the region
Table 2-15 Population, 1960-1980
exceeded substantially the rate of growth in
Oregon, which in turn exceeded the population
growth rate in the United States.
Seventy-four percent of the region's population
growth has been net migration into the region
(Seidel 1981). Surveys of recent immigrants imply
that many are coming to southwestern Oregon in
search of a perceived quality of life not found in
major metropolitan areas but available in small
urban and rural environments (Stevens 1981). A
significant proportion of the newcomers
immigrated to the region without having first
secured employment (Stevens 1980).
This immigration plus an increase in the
proportion of women employed or seeking
employment caused the labor force to grow faster
than total employment (Table 2-16). For example,
in Douglas County, the annual rate of job creation
was 2.17 percent while the labor force was
increasing at 2.91 percent annually.
Annual Growth Rate
County
1960
1970
1980
1960-70
1970-80
Douglas
Lane
Coos
Josephine
Jackson
68,458
162,890
54,955
29,917
73,962
71,743
213,358
56,515
35,746
94,533
93,748
275,226
64,047
58,820
132,456
0.5%
2.7
0.3
1.8
2.5
2.7%
2.6
1.3
5.1
3.4
Region
390,182
471,895
624,297
1 .9%
2.8%
Oregon
1,768,687
2,091,533
2,633,105
1.7%
2.3%
United States
179,323,175
203,235,298
226,504,825
1 .3%
1.1%
Source: U.S. Dept of Commerce Census of Population, years indicated.
Table 2-16 Components of Population Change, 1970-1980
County
Population
Change
1970-1980
Natural Increase
(Births minus
deaths)
Net
Migration
Net Migration
as a Percent of
Population Change
Douglas
Lane
Coos
Josephine
Jackson
22,015
59,825
7,532
23,109
37,923
7,332
19,657
4,391
2,224
5,867
14,683
40,168
3,141
20,885
32,056
67
67
42
90
85
Region
150,404
39,471
110,933
74
Source: Personal
Oregon, Septemb
communication,
er 1981.
Karen Seidel, Bureau
of Governmental Research
and Service, University of Oregon, Eugene,
50
Table 2-17 Average Size and Recent Growth of the Labor Force and
Employment in Industries
Douglas County
Regional
Regional Economy
Oregon
Compound
Compound
Compound
Douglas County
Annual Growth
Economy
Annual Growth
Oregon
Annual Growth
Avg. 1977-1980
1972-1980 O)
Avg. 1977-1980
1972-1980 ;
Avg. 1977-1980
1972-1980 (,)
l abor Force
38.800
291
270.500
3 75
1.202.500
358
Total Employment
35.000
2 17
246.300
3 23
1.1 16,800
3 38
Wage & Salary Empl>
BOO
246
210,900
1.009.100
3 77
All Manufacturing
1 0.200
-1 46
48.300
53
216.600
1 92
Lumber & Wood
8.500
-2 05
35.100
-2 64
77.700
-1 37
' Durable Goods
500
-.81
6.000
602
All Non-Manufacturing
20.600
4 75
162,500
4.87
792,400
4 30
5.600
4 44
50.100
5 10
245.500
4 67
Services & Miscell.i
4,300
683
35.900
6 72
1 78 600
565
Government
6.900
385
46,000
4 05
196.400
3 18
' Not comparable with the same category for Douglas County or the Regional Economy
Source Computations by EIS staff of data obtained from the Research and Statistics Section. Employment Division. Oregon Dept of Human Resources
Table 2-18 Total and Rate of Growth of
Labor and Proprietors' Income in
Selected Industries Affected by Timber Management in
District
the Roseburg
Douglas County
Avg. 1977-1979
(S1.000.000)
Douglas County E
Compound Annual
Growth 1972-1979
Regional
conomy Avg.
1977-1979
(S1. 000.000)
Regional Economy
Compound Annual
Growth 1972-1979
Oregon
Avg. 1977-1979
(S1.000.000)
Oregon
Compound Annual
Growth 1972-1979
Total Labor and Proprietors'
Income by place of work
S 493 5
1 1 .9
S3.073.5
12 96%
S19.792 8
1 1 40%
Durable Goods Manufacturing
197
10 1
837.1
10.60%
3.079 1
11 79%
Trade
57.9
555 2
13.81%
2,923.5
11.25%
Services
52.9
15 !.,
454.8
15.62%
2.381 9
12 40%
Federal Gov't., Civilian
26 6
10.99%
1023
12
505 7
7 97%
State and Local Government
Per Capita Personal Income
(in actual $)
253.1
$7,012.
3689
S6.984
12.55%
10.24
1.864 2
S 8.047
9 76%
9 38%
957%
Source Computations by EIS staff
1981.
obtained from the Regional Economic Information system US.
Department of Commerce, Bureau of Ecor
lomic Analysis. April
Employment and income growth in the region's
trade and service sectors was strong in the 1970's
(Tables 2-17 and 2-18). The growth rates in the
region outpaced Douglas County, which was
ahead of the State totals in both categories. A
reduction of the manufacturing base in Douglas
County and a lack of significant growth in
manufacturing employment in the regional
economy during the decade are of local concern
(C.C.D. Economic Improvement Assoc. 1978,
1979). Non-manufacturing employment within the
region and the State has increased, paralleling a
national trend. Whether projected long-term
declines in lumber and wood products
employment (Burden 1977; Flacco 1978; C.C.D.
Economic Improvement Assoc. 1978) can be offset
by continued growth in the non-manufacturing
sector and local programs promoting
diversification is still unknown (Oregon
Department of Human Resources 1979, 1980;
C.C.D. Economic Improvement Assoc. 1978, 1979;
Douglas County 1980).
Statewide, total employment in the lumber and
wood products sector declined at a 1.37 percent
annual rate (Table 2-17) and total employment in
manufacturing increased by more than 29,100
jobs, an average annual increase of almost 2
percent. To date, much of Oregon's diversification
and employment growth in manufacturing has
been in the Portland, Salem, Eugene-Springfield
and Medford metropolitan areas. The remainder of
western Oregon continues to be highly dependent
on agriculture and lumber and wood products for
significant proportions of its income and
employment. Since southwestern Oregon is
dominated by mountainous forest land,
agricultural options are limited. Thus,
overwhelmingly, the region's primary source of
income continues to be derivatives of the timber
resource — logs, lumber, plywood and other panel
products, chips, pulp and paper.
51
Receipts from the sale or use of resources found
on O&C, public domain and Coos Bay Wagon
Road (CBWR) lands are distributed to State and
local governments through distribution formulas
established by Congress and the Oregon
legislature. Fifty percent of the revenue from all
O&C lands in the State is distributed among the
counties with O&C land in proportion to the 1915
assessed value of the O&C lands in each county.
Tables 2-19 and 2-20 show the importance of O&C
revenue distribution to individual counties. The
summary data reported in Table 2-19 highlight
principal sources of revenue (as a percent of total)
and revenue per capita for Douglas County, all
counties in the EIS economic region and all
counties in Oregon. O&C revenues constitute a
significant portion of revenue from all sources for
Douglas, Coos, Lane, Jackson and Josephine
counties. The resulting high level of public
revenue per capita gives these counties
opportunities to provide a diversity and level of
public services more difficult to finance elsewhere
in Oregon (Jensen 1979). The value of these
disbursements to the O&C counties can be
equated in terms of property tax equivalents— the
amount per $1,000 assessed value which property
tax levies would have to be increased to raise an
amount of revenue equal to the county's share of
O&C receipts.
Payments are made to local governments from
CBWR land revenues in the form of timber
severance and property taxes. Severance tax
payments are distributed to local tax districts in
Table 2-19 County Revenue
Sources
as a
Percentage of Total Revenues
and County Revenues Per Capita for Fiscal Year 1977-78
Douglas
Regional Economy
All Oregon
Counties
% of Total
% of Total
% of Total
Source
Revenues
Per Capita Revenues
Per Capita
Revenues
Per Capita
I. REVENUES FROM OWN SOURCES
Tax Revenues:
Property Taxes
4,2%
$23.82
5 2%
S 16 27
16.6%
$35.76
Other Taxes
0,0
.00
0.2
72
1.7
56
Local Non-tax Revenues
Licenses, Permits,
Services Charges & Fees
2.8
15.67
4.2
12.94
5 1
1091
Fines. Forfeitures & Court Fees
1.3
7.22
1.7
5.19
2.0
4.38
Interest Earnings
40
2252
4.0
1294
3.4
742
Public Service Enterprises
1.7
9.50
1.1
338
1.9
4.02
Other Local Non-tax Revenues
Subtotal: Revenues from Own Sources
1.7
9.38
0.7
2.12
0.9
1 99
17.1%
S 53 17
31.6%
S68 04
II. INTERGOVERNMENTAL REVENUES
Federal Revenues:
General Revenue Sharing
1,1%
$6.14
1 .6%
$4 84
3.6%
$7.81
Federal Land Revenue Sharing:
National Forest Revenues
198
111 23
197
61.20
17 4
37.47
O&C Revenues
564
317.38
43.6
13576
206
4426
Payments in Lieu of Taxes
0,2
1.23
0.2
.61
0.7
1.48
Coos Bay Wagon Rd. Revenues
0.4
232
0.7
2.04
02
49
Other Land Revenue Sharing
0.0
.21
0.0
10
0.2
37
Grants-ln-Aid:
Anti-Recession Payments
0.5
281
0.5
1 61
1 1
245
Countercyclical Public Works
0,0
00
0.9
2.95
1 4
3.07
CETA
0.0
.25
1.2
3.72
2.7
583
Other Grants-ln-Aid
0,0
.00
3.2
982
4.1
868
State Revenues:
Shared Revenues
4 1
22 99
6.5
20 19
10.9
2331
Grants-ln-Aid & Others
1.5
8.37
3.5
10.92
4 2
9.12
Interlocal Revenues
Subtotal Intergovernmental Revenues
0.4
203
1.3
82 9
420
1.3
68 4
269
03
96
TOTAL REVENUES FROM
ALL SOURCES
100%
$56307
100%
$311 12
100%
S215.07
Source Oregon Bureau of Governmental Research and Service. Revenue Sources
• of Oregon Counties Fiscal Year
1977-78. Informatation Bulletin
No 171, Eugene. Oregon, June 1979.
52
Table 2-20 O&C Revenue Distribution to Counties Expressed As Property
Tax Rate Equivalent and As Percent Supplement to Total Levy, Fiscal
Years 1977-1980
County
Amount per $1,000 Assessed Value 1
1977 1978 1979 1980
Percent Supplement to Levy 2
1977 1978 1979 1980
Benton
$3.36
$2.26
$2.03
$2.05
21.9
12.3
12.4
10.5
Clackamas
1.69
1.17
1.01
.90
6.8
5.4
5.5
46
Columbia
2.20
1.77
1.86
1.86
15.2
12.7
13.0
11.7
Coos
6.59
5.32
4.81
4.59
30.9
31.9
29.0
25.3
Curry
13.27
9.81
8.38
7.09
120.2
102.1
92.9
109.2
Douglas
14.47
12.44
11.59
11.50
90.0
110.3
103.8
79.5
Jackson
9.78
6.90
5.85
5.51
50.5
39.3
41.2
330
Josephine
18.23
11.78
10.04
9.56
119.1
74.4
89.8
63.0
Klamath
2.47
1.85
1.73
1.68
17.3
13.4
13.7
11.7
Lane
3.92
2.91
2.48
2.36
17.1
14.1
13.6
11.6
Lincoln
0.45
0.40
0.33
0.31
3.4
2.5
2.2
1.6
Linn
1.77
1.39
1.37
1.30
9.4
8.2
8.5
7.1
Marion
0.62
0.43
0.39
0.36
2.6
2.0
2.0
1.7
Multnomah
0.13
0.09
0.08
0.08
0.5
0.4
0.4
0.4
Polk
3.91
2.75
2.43
2.41
16.2
13.6
13.1
12.2
Tillamook
1.38
1.14
1.03
0.93
8.2
7.7
6.4
8.7
Washington
0.19
0.13
0.11
0.10
0.8
0.6
0.6
0.5
Yamhill
1.09
0.75
0.67
0.64
4.9
3.7
3.6
3.1
Average
$3.01
$2.19
$2.54
$1.81
13.6
10.9
10.9
9.5
' Represents county O&C distribution for fiscal year (ending September 30) divided by total assessed value (in thousands) on January 1 of same
calendar year.
2 Represents O&C distribution as percent of total property tax levy for following year, e.g., FY 1977 distribution as percent of 1977-78 levy.
Source: USDI. BLM 1979a and 1980e. BLM Facts-Oregon and Washington, 1979, 1980; Oregon Dept of Revenue, Oregon Property Tax Statistics,
1978; Oregon Dept. of Revenue, Dick Yates, telephone conversations, April 15, 1980, June 24. 1980; Oregon Department of Revenue, Vinh Ninh,
telephone conversation, April 13. 1981.
Table 2-21 In-Lieu Tax Payment on CBWR Lands Administered by the
BLM in Douglas
County 1
Average Annual
Average CBWR
Disbursements
Average Annual
Property Tax
Average Budget Levy
(1979-1981) as a
Severance Tax Re-
Received 3
Submitted By Each Tax
Percent of Aver-
Tax District
ceived 2 (1979-1981)
(1977-1981)
District (1979-1981)
age Levy (1979-1981)
Douglas County
$ 2,929
$ 665
$2,078,000
0.2%
Oakland School
District I
207
68
1,230,000
• 0.1%
Camas Valley School
District 21
9,091
2,983
415,000
2.9%
Winston Dillard School
District 116
23,575
5,850
3,018,000
1 .0%
Douglas Education
Service District
2,235
622
2,740,000
0.1%
Umpqua Community
College
2,295
783
1,951,000
0.2%
Roseburg School
District 4
4
24
7,949,000
<0.1%
' Payments in-lieu of taxes are made to the county treasurer
and distributed to tax districts.
2 Severance tax is 6-1/2 percent of the value of the timber harvested.
3 Assessed value of forest land is a function of the price of second-growth Douglas-
ir stumpage over the most recent three-year period
4 The 27 acres of CBWR lands ir
i this school district are not forested with commerical species.
Source: Douglas County Assessor, Douglas County Treasu
rer.
53
accordance with timber assessed values on CBWR
lands prior to the institution of the severance tax.
In-lieu property taxes are calculated at levy rates
on the assessed value of land only. Table 2-21
shows the historical distribution of these payments
in Douglas County.
A net of 4 percent of revenues from public domain
lands is remitted to state governments. These
revenues in Oregon are distributed to counties on
the basis of total land areas for the benefit of
county roads and bridges. Receipts from the sale
of timber on public domain lands in the Roseburg
District were $902,700 in FY 1980 and $461,700 in
FY 1981. These receipts yielded $36,100 to Oregon
counties in FY 1980 and $18,500 in FY 1981.
Timber Industry
Approximately one out of every four workers
in Douglas County harvests, processes or
transports some type of wood product (ratio of
lumber and wood products employment to total
employment, see Table 2-17). For the region, one
out of every seven workers is actively engaged in
the flow of wood products. In contrast, for all
Oregon workers, only one in every 14 is employed
in the wood products industry.
During 1977-78, 40 percent of all wages paid in
Douglas County (in sectors covered by State and
federal employment insurance programs)
originated in the wood products sector. For the
region, the same figure is 27 percent and for
Oregon, 12 percent.
The Roseburg District plays a significant role in
providing raw material to the lumber and wood
products sector. For example, during the 1976-
1977 period, 13.5 percent of the Douglas County
harvest came from the Roseburg District (Table 2-
22). BLM's Medford, Coos and Eugene Districts
also administer land in Douglas County.
Table 2-22 Timber Harvest (MM
bd. ft. Scribner long log volume) by
Ownership Class, Douglas County
1976
1977
All
Ownerships
1.308.3
1.269.1
BLM
3439
2995
Roseburg
District
199.7
1476
Source: Oregon Department of Forestry and Roseburg District
Historical data underscore the role of BLM
stumpage in log processing within Douglas
County. These data show that sawmill and
plywood and veneer facilities in the county have
become increasingly dependent on BLM timber.
Conversely, processors statewide are looking less
and less to Bureau lands for log supply (Table
2-23).
The timber management program on the Roseburg
District affects the regional economy employment
and personal earnings in three ways: 1) the harvest
and processing of the timber; 2) site preparation,
replanting and subsequent management of
harvested units; and 3) the disbursement of O&C
revenues.
The economic effects of timber harvest,
processing, reforestation, intensive management
and O&C disbursements to counties in the region
stem from the average annual harvest and the
value of the sale units harvested. During the 1976-
1980 period, harvest of BLM timber in the
Roseburg District averaged 187.5 MM bd. ft. and
the typical unit yielded $157 per M bd. ft. (Table 2-
24). This average annual harvest and value of
receipts supported more than 3,200 jobs in the
region, including over 2,400 jobs in Douglas
County. The payrolls associated with this
employment equaled $32 million in Douglas
County and $50.1 million in the region (Table
2-25).
Fishing, Hunting and Other
Recreation
The annual economic effects of expenditures
made by persons engaged in commercial and
sport fishing, hunting and general recreation are
listed in Table 2-26. In total, the production of
these three resource categories on Roseburg
District BLM-administered lands generates the
equivalent of 109 full-time jobs and $568,000 in
local personal income each year.
Social Concerns
Timber, as the main economic support of the
local economy, greatly influences social attitudes
and concerns of residents. Individual economic
welfare is often closely related to the welfare of the
timber industry. The current depression in the
local economy has raised concern about the
timber industry.
The fluctuations of the industry have required
people to adjust to changes in their welfare. For
example, Figure 2-4 shows the expansions and
contractions which took place in the lumber and
wood products sector in Douglas County between
1970-1980. While the average level of employment
for the decade was 8,565, the average annual level
of wage and salary workers ranged from a high of
9,150 in 1973 to a low of 7,600 in 1980.
Furthermore, forecasts of a dwindling timber
supply (Beuter et al. 1976, Stere et al. 1980, Rahm
1980, U.S. Forest Service 1980) in the Pacific
Northwest and projections of declining lumber and
wood products employment (Bruner and
Hagenstein 1981) in one or two decades are likely
to increase concern about the timber supply.
54
Table 2-23 Dependency of Log Processors in Oregon and Douglas County
on BLM Timber (All processing estimates in M bd. ft.)
Origin of logs consumed by sawmills in Oregon by
1976 3
ownership class 1968 1 , 1972 2 and
All Ownerships
BLM
% BLM of Total
Processed
1968
1972
1976
Douglas
Douglas
Douglas
532,340
632,863
519,915
167,408
233,868
222,236
31.4
37.0
42.7
1968
1972
1976
Oregon
Oregon
Oregon
5,863,324
6,140,629
5,404,346
740,227
801,034
642,920
12.6
13.0
11.9
Origin of logs consumed
and county
1968\1972 2 and1976 3
by plywood and veneer m
ills in Oregon by ownership class
1968
1972
1976
Douglas
Douglas
Douglas
591,560
565,466
599,983
183,707
268,500
252,010
31.1
47.6
42.0
1968
1972
1976
Oregon
Oregon
Oregon
3,578,494
3,650,016
3,305,705
655,670
714,334
584,241
18.3
19.6
17.7
1 Manack, Eugene R., Choate, Grover A., i
State of Oregon Dept. of Forestry.
* Schuldt, John P., and James 0. Howard,
427, Dec. 1974, 113 p.
Howard, James 0.. and Hiserote, Bruce
nd Gedney. Donald R., Oregon Timber Industries: Wood Consumption and Mill Characteristics 1968.
Oregon Forest Industries, 1972 Wood Consumption and Mill Characteristics, OSU Special Report No
\., Oregon's Forest Products Industry 1976, USDA Forest Service Resource Bulletin PNW-79. 1978.
Table 2-24 Harvest Sales and Receipts, BLM Timber in the Roseburg
District (FY 1976-1980)
Fiscal
Sale
Removals
Value of Sales
Value of Receipts
Year
(MM bd. ft.)
(MM bd. ft.)
($1,000,000)
($1,000,000)
1976
232.3
165.6
35.0
20.9
Transition Quarter
49.6
82.8
6.5
13.7
1977
188.8
212.2
29.1
39.2
1978
185.7
198.3
30.4
27.9
1979
188.1
169.9
45.5
27.2
1980
190.5
155.4
56.9
26.1
Average 12 month harvest, 1976-1980: 187.5 MM bd. ft.
Average value per M bd. ft. removed: $157
55
Douglas
County
Regional
Economy
187.5
187.5
1,106
1,388
$15.8
$20.3
1,106
1,331
4,300
4,300
38
38
$0.3
$0.3
19
19
Table 2-25 Average Annual Local Economic Effects of Timber
Management on Lands Administered by the Roseburg District (1976-1980)
Total for
Average Harvest Volume (MM bd. ft. Scribner Short Log Rule) 1976-1980
Number of Local Jobs Provided by Harvesting and Processing 1
Annual Local Payroll Generated by Harvesting and Processing ($1,000,000)
Number of Local Jobs Produced in Other Business Sectors Resulting from
Payrolls Created by Harvesting and Processing'
Annual Local Payroll in Other Business Sectors Created by Harvesting and $10.4 $13.8
Processing ($1,000,000) 2
Acres Harvested Each Year
Number of Local Jobs in Reforestation and Intensive Management 1
Annual Local Payroll in Reforestation and Intensive Management ($1,000,000) 2
Number of Local Jobs Produced in Other Business Sectors Because of
Reforestation and Intensive Management on Lands Administered by the Roseburg
District 1
Annual Local Payroll Produced in Other Business Sectors Because of $ 0.1 $ 0.1
Reforestation and Intensive Management on Lands Administered by the Roseburg
District ($1,000,000) 2
Public Revenue to County Governments Attributable to the Harvest ($1,000,000 $ 3.7 $10.9
in O&C Disbursements)
Number of Employees of County Government Whose Jobs Depend Upon Public 73 214
Revenues from the Sale of BLM Timber Obtained from Lands Administered by the
Roseburg District
Annual Payroll of County Government Employees Whose Jobs Depend Upon $0.8 $2.2
Public Revenue from the Sale of BLM Timber Obtained from Lands Administered
by the Roseburg District ($1,000,000) 2
Number of Local Jobs Produced in Other Business Sectors Because of County 79 232
Employment Dependent on O&C Disbursements and the Jobs Created by
Disbursements Passed Through to the Local Economy in the Form of Capital
Construction or County Support of Local Programs
Annual Payrolls in Other Business Sectors Dependent on County Payrolls $0.9 $2.5
Created By Disbursements Passed Through to the Local Economy in the Form of
Capital Construction or County Support of Local Programs ($1,000,000) 2
Total Local Employment Effect of the Timber Management Program 1
Local employment effect per MM bd. ft. of BLM timber harvested
Local earnings per MM bd. ft of BLM timber harvested
Total Local Payroll Effect of the Timber Management Program
($1,000,000) 2
' All estimates refer to full-time employment, e.g., two jobs of 6-month duration equal one full-time equivalent.
•'1976- 1978 dollars.
2,421
3,222
12.9
17.2
$150,900
$209,100
$28.3
$39.2
56
Table 2-26 Local Economic Effects
of Fisheries, Terrestrial Wildlife and
General Recreation
Employment
Earnings'
Fisheries
Direct
Indirect
25
10
130.000
76,000
Hunting
Direct
Indirect
15
6
64,000
36,000
Other Recreation
Direct
Indirect
38
15
163,000
99,000
Total
109
568,000
1 1976-1978 dollars
The seasonal variations in timber industry and the
longer fluctuations in employment attributable to
market conditions have produced a kind of dual
work force in the industry consisting of a core of
stable, senior workers and a peripheral group of
workers who "float" in and out of the industry in
response to the job situation or higher pay
(Stevens 1978).
Herbicide use is a controversial issue having many
vocal advocates and opponents. Advocates believe
it is an inexpensive and safe means of increasing
timber production by controlling competing
vegetation when used with proper safeguards.
Opponents believe further evidence is needed to
prove that herbicide use is less expensive than
other means. They also believe herbicide use may
be damaging to the environment and harmful to
human health.
Also controversial with some adjoining landowners
and other residents are clearcutting and
anticipated damage to watersheds from harvesting
timber on steep slopes.
FIGURE 2-4
CO
UJ
LlJ
>-
o
Annual Average Lumber and Wood Products Employment
Douglas County, Oregon 1 970 -1 980
10,000
9000
8000
£ 7000
rr
UJ
GO
2 6000
3
1970
71
72
73
74
75 76
YEAR
77
78
79
80
57
Table 2-27 Changes Desired by Survey Respondents in the Use of Federal
Lands
(Percent distribution omitting undecided respondents)
Oregon
Southern Oregon
No
No
Use
More
Change
Less
More
Change
Less
Wildlife habitat
61
30
8
49
36
14
Hiking/Camping
52
38
8
40
46
12
Wilderness
44
38
16
32
28
39
ORVs/snowmobiles
13
24
60
19
33
44
Timber Production
41
38
19
60
26
13
Hunting/Fishing
51
40
7
53
42
4
Source: Tiff Harris, Public Perceptions of Federal Land Use Decisionmaking in Oregon: Results of a State-wide Survey, Oregon State University.
August 1979
A recent statewide survey by Bardsley and
Haslacher (Harris 1979) showed that residents of
southern Oregon (including Douglas County) have
different attitudes about the use of federal lands
than do Oregonians in general. These survey
results are shown in Table 2-27.
Local Employment and
Personal Earnings Attributable
to Resources Produced by
BLM-Administered Land
In summary, the principal sources of local
employment and personal earnings attributable to
resources produced on BLM-administered land in
the Roseburg District are:
Resource Employment Earnings
Timber 3,222 $39,200,000
Commercial and Sport
Fisheries
Hunting
Other Recreation
35
206,000
21 100,000
53 262,000
3,331 $39,768,000
59
Chapter 3 Environmental
Consequences
Introduction
In this chapter, environmental consequences
(impacts) are compared to the existing situation,
as described in Chapter 2. Economic impacts are
based on the existing situation plus projections of
price and revenue levels under Alternative 5 (No
Action). The significant impacts resulting from
implementation of each of the alternatives are
analyzed in relation to these baselines. A tabular
comparison of composite impacts from each
alternative is shown in Table 1-5. Analysis,
including the scoping process, indicates that
timber management would have no significant
impacts upon climate, geology, topography,
minerals, grazing, agriculture, utilities,
communication sites and wilderness. Therefore,
these topics are not discussed.
The major actions which cause impacts are timber
harvest, road construction, site preparation
(includes slash burning and herbicide use),
plantation maintenance and release, plantation
protection, precommercial thinning and
fertilization. Significant effects to the local area
and its economic base can also occur, depending
upon which alternative and harvest volume levels
are ultimately selected. These would include
changes in employment, personal income and
sharing of sale receipts with county governments,
school districts and other local taxing entities.
60
In analyzing the impacts of the Original Proposed
Action (Alternative 4), a sample 5-year (1984-1988)
timber sale plan (available for review at the
Roseburg District Office) was developed and used,
where applicable, to assess potential site specific
timber sale impacts. Although a 5-year plan is
used for analysis purposes, actions identified are
considered typical for the entire decade. Possible
conflicts identified in this chapter for specific sales
will be thoroughly addressed in detailed site
specific environmental assessments. Timber
management treatments not included in the timber
sale plan (planting, vegetation control with
herbicides, animal damage control, precommercial
thinning and fertilization) are analyzed at the
proposed 10-year levels. Site specific
environmental assessments will be prepared when
specific acreages are identified for each treatment.
Analysis of the alternatives is based on the
different levels of treatments shown in Table 1-2.
Two time frames are used in the analysis process.
The short term is the first 10 years following the
adoption of a new timber management plan. The
long term is defined as beyond 10 years. Other
time periods pertinent to specific impact
discussions are used as necessary and identified
in the text.
Analysis of long-term impacts for all alternatives is
based on the assumption that the alternatives
would be continued for many decades. In fact, the
10-year timber management plan and related land-
use allocations selected after completion of the
EIS will be subject to revision at the end of one
decade.
A basic assumption of the analysis is that
sufficient funding and personnel will be available
for implementation of the final decision.
Impacts on Air Quality
During the construction of new roads and
maintenance of older roads, fine particulate matter
would be disturbed. This dust settles back to earth
in relatively short distances, does not adversely
impact anyone away from the construction sites
and thus will not be considered further.
The major impact to air quality in the SYUs would
be from slash burning. Estimated levels of burning
activity by alternative are given in Table 1-2 (Site
Preparation/Broadcast Burning).
Regardless of the alternative selected, all burning
would be done in accordance with the Oregon
Smoke Management Plan. Normally, smoke would
be carried into upper air levels and away from
populated areas. Occasionally, unforecasted
weather changes could cause some smoke to
return to surface areas, causing visible intrusions
in nearby residential areas. When slash fires are
allowed to burn or smolder overnight, the cooling
nighttime temperatures bring residual smoke down
valleys, causing problems with visibility and
increased particulates. The probability of intrusion
would be highest under Alternative 1, due to more
acres burned, and lowest under Alternative 8. Past
experience indicates that visible intrusions may
affect the population centers of Eugene-
Springfield and Roseburg. Reported smoke
intrusions from BLM Roseburg District slash burns
affected the area from Roseburg to North Bend in
1980 (OSDF 1981). Between 1976 and 1981
Roseburg BLM was responsible for 18 of the 56 (32
percent) reported smoke intrusions in Douglas
County. None of the intrusions during the above
period led to a violation of primary air quality
standards for total suspended particulates (Table
2-1).
Since 1980, there has been an effort to shift the
prescribed fire workload from the traditional fall
season to spring and early summer. It is estimated
that 30 percent of the prescribed fire workload will
occur in the spring and early summer. This is the
season of best smoke dispersion opportunities. In
the spring, larger fuels and the duff have fuel
moistures too high to sustain fire. This results in
less volume consumed and a corresponding
reduced volume of smoke. Climatic conditions in
the spring also increase the efficiencies of
prescribed fire mop-up activities, resulting in less
residual smoke. The trend in increasing wood
utilization is also contributing to less volumes of
slash occurring on harvested areas. These
emission reduction techniques contribute to an
estimated 35 percent decrease in volume of smoke
produced per acre burned (Sandberg 1983). This
data does not allow a statistically correct
projection of expected problems over the next
decade.
Airborne particles less than 1.0 micron in diameter
make up 80 percent of smoke particulates.
Particles of this size have very low fall velocities,
about 5 cm/hour, and therefore will travel
distances of approximately 100 miles. Particles of
this size also scatter visible light (0.3 microns blue
to 0.8 microns red), causing visibility problems.
Depending on the wind direction and speed
following slash fires, visibility intrusions could
occur in the Eugene-Springfield AQMA, the
Roseburg AQMA, and in the following Class I
areas: Kalmiopsis, Crater Lake, Mt. Washington,
Three Sisters, Mt. Jefferson and Diamond Peak.
The wood component of slash is made up of about
50 percent carbon, 6 percent hydrogen, 43 percent
oxygen and small amounts of nitrogen and other
elements. When burning occurs, temperatures of
570° F to 2550° are maintained (Hall 1972) which
produce carbon dioxide and water vapor. The
whitish column of smoke observed from controlled
slash fires is made up of over 90 percent water
vapor and C0 2 (Table 3-1 ).
61
Table 3-1 Avi
verage Emission Components From Slash Burning (Tons/Decade)
ALTERNATIV
1
2
3
4
5
6
7
8
9
Max. Tbr.
Emp. Tbr.
LoMHS
OPA
No Action
HD
No Herb.
Full Eco.
NPA
Tons of Slash
182,308
167,654
161,487
157,105
120,922
115,472
108,269
54,369
155,826
Burned
Particulates'
3.828
3,521
3,391
3,299
2,539
2,425
2,274
1,142
3,273
Hydrocarbons
2,279
2,096
2,019
1,964
1,512
1,443
1,353
680
1.948
Carbon Monoxide'
23,700
21,795
20,993
20,424
15,720
15,011
14,075
7,068
20,262
Sulfur Oxides 4
Negl
igible
Nitrous Oxides 5
365
335
323
314
242
231
217
109
312
Water Vapor and
Carbon Dioxide 6
90%
of the Mass of Combustion Products -
' Particulates are near 0.1 micrometer in diameter. Average emission of 17-67 pounds/ton slash burned.
2 Hydrocarbons are a diverse class of compounds containing hydrogen, carbon and oxygen.
3 Carbon monoxide (CO) is very short lived in the natural environment and quickly dilutes and also converts to C0 2 .
4 Sulfur oxides (SOx) are produced in small quantities, since most forest residues contain less than 0.2 percent sulfur
5 Nitrogen oxides (NOx) are found in some very hot fires, but this is generally not a problem in prescribed burns. The temperature
required to fix atmospheric nitrogen is over 2800° F and such a temperature is not frequently attained in slash burns.
6 Carbon Dioxide (CO,) is not an air pollutant in the usual sense. About 1 ton of burned fuel produces 1 to 1-1/2 tons of C0 2 (Ryan et
al. 1976, cited in Sandberg et al. 1978).
Source: J Alfred Hall 1972 and Sandberg et al. 1978
The contaminants most frequently found in slash
smoke are carbon dioxide (C0 2 ), carbon monoxide
(CO), nitrogen oxides (NO x ), hydrocarbons (HC)
and respirable fine particulates (Sandberg et al.
1978).
Conclusions
The major impact to air quality would be
visible smoke from slash burning. Although
occasional smoke intrusions are likely, none are
expected to violate primary air quality standards
for total suspended particulates.
Impacts on Soils
The major impacts of timber management on
soils are compaction, landsliding, topsoil erosion
and depletion of organic matter, nitrogen and
other nutrients. Each results in a loss of soil
productivity (see Glossary). Timber management
activities that are the causal agents include road,
fire trail and landing construction; yarding logs;
scarification and slash burning. The amount of
landslides and surface erosion is influenced by the
steepness of slopes, soil properties, amount of
disturbance and remaining litter cover, and the
amount and intensity of precipitation (Pritchett
1979).
Standard design features would be employed to
minimize adverse impacts on soils. Compacted
soils from tractor logging in clearcut units would
be ripped or tilled to partially restore productivity.
Loss of productivity due to compaction from
tractor logging in partial cut units cannot be
mitigated during the rest of the rotation. Partial
and total suspension yarding systems would be
used to minimize soil disturbance. New roads
would be located away from streams and on
ridgetops and designed to avoid undercutting or
overloading unstable slopes. Excess road material
on unstable and potentially unstable slopes would
be end-hauled to reduce landsliding. Scarification
would be done during dry soil conditions without
piling soil. Slash burning and scarification would
be minimized on thin, droughty or nitrogen-
deficient soils.
Table 3-2 shows estimated acres upon which soil
productivity would be lost as a result of timber
management under the proposed action and
alternatives during the first decade.
Soil compaction results primarily from the weight
and shearing forces involved in dragging logs and
operating ground-based logging equipment.
Compaction hinders root penetration and water
percolation and availability, reducing vegetation
growth. Decreases in root penetration of 35 to 65
percent can reduce the vegetative productivity of
soils by 10 to 25 percent (Power 1981a). In the
Roseburg SYUs, tractor logging has been found to
reduce soil productivity for the entire cutting unit
by 11.8 percent due to compaction (Wert and
Thomas 1981). Yarding systems using ground-
based equipment have a greater adverse impact on
soils than cable systems which drag the logs. One
end suspension has a lesser impact than systems
providing no suspension. Systems using total
suspension have the least impact on soils.
Compaction and reduced infiltration capacity have
been found to last at least 55 years (Power 1974,
cited in Fredriksen and Harr 1979) and therefore
may last longer than harvest rotation periods.
Site scarification and slash piling by tractors with
brush rakes compacts soils and displaces topsoil.
This practice can be expected to reduce soil
62
Table 3-2 Estimated Loss of Productivity During First Decade (acres) 1
Process
Road
Construction 2
Yarding Systems
(Compaction) 3
Landsliding from
Fragile Soils
Dry Ravelling
Nutrient Depletion
Totals
Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6 Alt. 7 Alt. 8 Alt. 9
Max. Emp. Lo No No Full
Tbr. Tbr. MHS OPA Action HD Herb. Eco. NPA
5,568 5,124 4,932 4,800 3,696 3,528 3,306 1,662 4,780
3,551 3,267 3,135 3,057 3,132 2,250 2,131 980 3,056
11
10
17 16 15 15
Acreage data unavailable
Acreage data unavailable (see Table 3-3)
9,136 8,407 8,082 7,872 6,839 5,788
10
15
5,447 2,647 7,851
' Productivity loss of commercial timber resulting from road construction and landslides is long term. Loss from compaction has been
estimated to last up to 55 years on some soils.
2 From Table 1-2.
3 These are equivalent net acres (acres compacted x percent loss of productivity due to compaction) assuming amelioration by
ripping.
productivity by 11 to 22 percent (Clutter and Dell
1978). One study in the Salem District showed a
reduction of 17 percent in productivity after
scarification (Power 1981b). Topsoil is also
removed by dragging logs and by constructing fire
trails, roads and landings with heavy equipment.
On clearcuts yarded by tractors, predesignated
skid roads will be used so that less than 10 percent
of the surface area will be traversed.
On very steep slopes with decomposing granitic
bedrock, clearcutting increases the number and
magnitude of debris avalanches and torrents. This
increase is caused by decay of small tree roots, log
gouges from yarding, plugged road culverts and
road construction and usually occurs 1 to 3 years
after harvesting (Hughes and Edwards 1978). The
5-year timber sale plan shows 825 acres of soils
from granitics would be subjected to timber
harvest.
Erosion from landslides in Tyee sandstone, as
measured in the Mapleton Ranger District
(Swanson, Swanson and Woods 1977), increases
123 times above the undisturbed forest rate
following clearcutting and roadbuilding.
Approximately 4,600 acres of these soils, identified
as fragile, would be harvested as shown in the
sample 5-year timber sale plan.
Estimates of acres of soil lost due to landsliding
are given in Table 3-2. The size of potential
landslides ranges from 20 to 250 feet wide and 200
to 6,000 feet long. Material from such slope
failures usually scour stream channels to bedrock,
ending in debris dams.
Dry ravelling in disturbed areas takes place
throughout the year in the SYUs and results in loss
of topsoil and decreased soil depth. When
vegetation and duff are removed by yarding logs,
slash burning or other practices, surface soil is
free to move and ravelling is accelerated. On
steep, south-facing slopes ravelling may continue
for 20 to 30 years after disturbance or until
vegetation becomes reestablished.
Nitrogen (N) in forest soils is largely in the humus
layer. Amounts of 2 to 10 tons per acre can be
found in deep silt loams under old growth
Douglas-fir (Heilman 1981). Much of this N in the
slash and litter is volatilized during slash burning
and is lost. Total loss of N from clearcutting and
slash burning can reach as high as 9 percent of
available N (Hornbeck et al. 1974, in Sopper 1975),
but more likely will be about 4 percent (Grier
1982). Losses of phosphorus (P) are similar to
Table 3-3 Expected Nutrient Losses
(Tons) from Timber Harvesting and
Slash Burning (10-Year Plan)
Alternative
N
P
K
Ca
1 (Max Tbr )
3.076
3.691
344
850
? (Emp Tbr)
2,829
3,394
316
782
3 (Lo MHS)
2.725
3.269
305
753
4 (OPA)
2.651
3.181
296
733
5 (No Action)
2.040
2 448
228
564
6(HD)
1.949
2.338
218
538
7 (No Herb )
1.827
2.192
204
505
Eco.)
917
1.101
103
254
9 (NPA)
2,640
3.170
295
731
Source: Based on analysis of a 35-year-old. second growth
Douglas-fir ecosystem.
63
losses of N. Losses of nutrients calcium (Ca) and
potassium (K) are a little less than N and P
(Fredriksen 1972; Grier, personal communication).
These nutrients are attached to organic detritus
and soil particles and are lost as the soil erodes.
Assuming a 4 percent loss of N and P, and a 3
percent loss of Ca and K following clearcutting
and burning (site preparation), each alternative
would result in losses shown in Table 3-3.
Conclusions
Impacts to soil and soil productivity are
mainly due to road construction, landslides, and
compaction. Alternative 1 has the greatest impacts
on long- and short-term soil productivity while
Alternative 8 has the least. Acres lost from
production range from 2,647 under Alternative 8 to
9,136 under Alternative 1. Less signifcant impacts
include nutrient losses, dry ravelling, and topsoil
removal.
Impacts on Water
Resources
Forest management activities which would
impact water resources include road building,
timber harvest, slash burning and application of
fertilizers and herbicides. These activities can
affect water yields, seasonal streamflow
characteristics (peaks and low flows) and instream
water quality (sedimentation, temperature,
dissolved oxygen, nutrients and organic
substances). The significance of each impact
would depend upon the amount of timber
harvested in each watershed, the proximity of the
activities to streams and the site specific
application of mitigating measures.
Water Quantity
Forest harvest activities would have very
little effect on the streamflow of larger rivers
draining the SYUs. Table 3-4 shows estimates of
annual water yield from public lands in the SYUs
for each alternative, compared to the existing yield
and undisturbed watershed.
Although the effect of timber harvest on
streamflow in the larger rivers would be small,
local increases in water yield would occur in
clearcut areas. Removing forest vegetation
reduces evapo-transpiration (see Glossary),
thereby increasing the amount of rainfall available
for streamflow. Studies of clearcutting small
watersheds in western Oregon showed that water
yields from clearcut areas increased 26 to 43
percent following harvest (Harris 1977; Rothacher
1970; Harr et al. 1979). Based on Rothacher's
(1970) study of clearcutting in the central Oregon
Cascades, water yield from clearcut areas in the
SYUs is expected to increase 35 percent. The
duration of increased water yields is not easily
predicted; however, varying degrees of altered
yields may last up to 35 years (Kovner 1956, cited
Table 3-4
Estimated
Annual Water
Yield From BLM- Administered Land,
End of First Decade
Percent
Percent
Annual
Change
Change
Water Yield
From
From
Situation
(acre-feet)
Existing
Undisturbed
Past Decade
863,000
44
Alt. 1 (Max. Tbr.)
879.000
1.8
63
Alt. 2 (Emp. Tbr.)
875.000
1.3
5.8
Alt. 3(LoMHS)
873.000
1.1
56
Alt. 4 (OPA)
872,000
1.0
5.4
Alt. 5 (No Action)
864,000
0.1
46
Alt. 6(HD)
860,000
-0.4
4.0
Alt. 7 (No Herb.)
858,000
-0.6
38
Alt. 8 (Full Eco.)
841.000
-2.5
1.8
Alt. 9 (NPA)
871.000
0.9
5.3
Source: Based on
analysis of a 35
-year-old,
second growth
Douglas-fir ecosystem.
in Harr et al. 1979). Compacted soils and roads
which increase surface water runoff are permanent
sources of water yield increases.
In addition to altering total annual water yields,
timber harvest would affect the timing and
magnitude of seasonal streamflows in small
watersheds in the SYUs. Rothacher's (1970, 1973)
study of small watersheds near the SYUs showed
fall and spring peak flows were increased by
logging, although extreme winter peaks were
relatively unaffected. A recent analysis (Christener
1981) suggests that extreme winter peaks may also
be increased by timber harvest if the peaks occur
from heavy rainfall on an existing snowpack.
Summer low flow levels would also be increased
by timber harvest. Studies of other small
watersheds in the central Oregon Cascades
(Rothacher 1971) suggest minimum flows for small
watersheds in the SYUs would increase up to 300
percent. Although relative changes in minimum
flows may be large (200 to 300 percent), absolute
changes would be small, due to naturally low
levels of streamflow during the summer months
(ibid.). Increases in peaks and low flows would be
greatest in small watersheds sustaining the
greatest increases in clearcut acreages during the
next decade.
Water Quality
Timber harvesting, road building and slash
burning would increase sediment discharge from
affected small watersheds in the SYUs. Fredriksen
and Harr (1979) reported that logging in the
central Oregon Cascades increased suspended
sediment yield 23 times the natural rate
(undisturbed condition) in a patch cut watershed
with roads, and nine times the natural rate in a
clearcut watershed without roads. Hughes and
Edwards (1978) reported that sluice-outs from
intermittent streams in clearcuts were eight times
as large (on a per acre basis) as from intermittent
streams in undisturbed watersheds, and most (85
64
percent) resulted from headwall failure. These
sluice-outs originated in granitic soils (Holland-
Siskiyou series) during storms of 5 to 12 year
return periods (see Impacts on Soils). Clearcut
acres produced about 530 tons/acre of sediment
from landslides in granitic soils. Similar increases
in sediment yield can be expected in small
watersheds within the SYUs where mass soil
movement (debris avalanching) is the dominant
erosion process (see Impacts on Soils). In
undisturbed watersheds, streams are usually
capable of transporting more sediment than is
delivered to them (Rice et al. 1979). During and
following timber harvest, road construction and
slash burning, sediment and debris would be
delivered to drainage systems. Sediment discharge
would then no longer be determined by the
availability of sediments, but by the transporting
ability of streams. Increased water yields (Table 3-
4) would also increase the ability of streams to
transport sediments. Where stream energy is
insufficient to transport all the sediment,
deposition would occur.
Surface vegetation left undisturbed in areas
bordering streams can act as a filter and retain soil
particles eroded from the surface of disturbed
areas, thereby reducing suspended sediments in
streams. The effectiveness of sediment buffers is
dependent upon slope, type and density of
vegetation and buffer width. When water
temperature is not a concern and careful planning
is used in partial cutting of buffers (falling timber
away from streams, no tractor harvest and no
burning), the removal of merchantable timber may
not adversely affect the sediment trapping ability
of the buffer (Froehlich 1982). Buffers would
protect third order and larger streams in
Alternatives 2 through 7 and 9, and protect all
streams in Alternative 8. In Alternative 1 no harvest
restrictions are planned for stream buffers except
as provided by the Oregon Forest Practices Act.
When buffers are left on third order and larger
streams, only sediment produced from first and
second order streams will enter at the headwaters
and be carried down the drainage system
whenever stream energy is sufficient for transport.
Sediment yield from surface erosion and runoff
was estimated by examining the number of acres
of buffers harvested in each alternative and is
displayed in Table 3-5. The percent of the buffers
to be cut was used to estimate sediment yield
(Table 3-6) and altered water temperatures.
Estimates of total sediment yield are presented in
Table 3-6.
Table 3-5 Estimated Sediment Yield
Through Buffer Strips
(For First Decade)
Acres of
Proposed
Tons of Sediment
Buffers to be
From Sheet
Alternative
Harvested
Erosion
Clearcut
Partial cut
1 (Max. Tbr.)
N/A'
N/A'
303,000
2 (Emp. Tbr.)
127
1,018
176.800
3 (LoMHS)
121
981
153,800
4 (OPA)
120
960
148,900
5 (No Action)
40
310
164,600
6 (HD)
7 (No Herb.)
8
660
102,900
8 (Full Eco.)
9(NPA)
1 No harvest restrictions are planned.
The chemical quality of surface water would be
affected by slash disposal. In one Oregon
Cascades watershed studied by Fredriksen (1971),
instream concentrations of ammonia-nitrogen and
manganese reached peak levels of 7.6 and 0.44
parts per million (ppm), respectively, when runoff
from rainfall that extingushed the burn entered the
stream. In the SYUs, only Alternative 8 would
provide adequate protection for streams.
Ammonia-nitrogen and manganese concentrations
could exceed recommended water quality
standards (0.02 ppm for free ammonia-nitrogen,
0.05 for manganese) in some first and second
order streams for several days following slash
burning. However, water from these streams would
quickly be diluted upon entering third order or
larger streams, resulting in a slight, short-term
impact.
Due to insignificant surface runoff in areas to be
fertilized, substantial increases in nutrient
concentrations following forest fertilization are not
expected in the SYUs. Pelleted urea dissolves
slowly and is utilized by vegetation before it can be
translocated.
Timber harvest affects stream temperatures by
removing shading vegetation from streambanks.
Stream temperature increases of 10 F or more
have been recorded following removal of
streamside vegetation by clearcutting and burning
in both the Oregon Cascades and Coast Range
(Brown and Krygier 1970; Levno and Rothacher
1969). Alternative 8 provides temperature
maintenance for first order and larger streams.
Under Alternative 1, removal of merchantable
timber (see Table 3-5) would reduce the
effectiveness of buffers to provide adequate shade,
resulting in increased temperatures. Downstream
shading does not significantly lower temperatures
of streams warmed by upstream exposure (Brown
etal. 1971).
65
Table 3-6 Estimated Sediment Yield From BLM-Administered Land,
First Decade
(Tons/Decade)
From
From
Alternative
Landslides
Sheet Erosion
From Roads
Total
1 (Max. Tbr.)
84,100
303,000
104,400
491,500
2 (Emp. Tbr.)
77,300
176,800
61,000
315,100
3 (Lo MHS)
74,500
153,800
53,000
281,300
4 (OPA)
72,500
148,900
51,400
272,800
5 (No Action)
55,800
164,600
56,800
277,200
6(HD)
53,300
46,000
99,300
7 (No Herb.)
49,900
102,900
35,500
188,300
8 (Full Eco.)
25,100
17,800
42,900
9 (NPA)
72,300
51,200
123,500
Harvest activities may reduce instream
concentrations of dissolved oxygen by adding
debris to streams. Fine organic debris (such as
small twigs and needles) uses dissolved oxygen
during decomposition. This depletes dissolved
oxygen concentrations at times of high stream
temperatures, low streamflows and low available
oxygen. Since instream oxygen concentrations
quickly return to normal following stream cleanout
and fall rains (Hall and Lantz 1969), low instream
oxygen concentrations would only be local and
temporary in the SYUs. However, oxygen
concentrations in stream gravel may continue to
decline for several years after logging, because
waterflow through gravels is restricted by
sedimentation (Hall and Lantz 1969). For this
reason, impacts on intragravel oxygen in the SYUs
would be directly related to the changes in
sediment yield discussed above.
The effects of herbicide application on water
quality have been described elsewhere (USDI,
BLM 1978). Design elements (see Chapter 1) such
as buffer strips are expected to minimize herbicide
drift or accidental direct spraying of water bodies.
Amounts of herbicide reaching streams beyond
these barriers would be insignificant and would
not adversely affect water quality. Movement of
herbicides through the soil (leaching) is usually
measured in terms of inches or a few feet (Norris
1975). This is a slow process that would not lead to
stream contamination, because the herbicide
would degrade before reaching free water (ibid.).
For additional discussion, see Chapter 3, Impacts
on Animals and Impacts on Human Health.
Municipal Watersheds
The cities of Riddle, Canyonville and Drain
have signed Memoranda of Understanding (MOU)
which outline practices to be utilized in the
municipal watersheds. The sample 5-year timber
sale plan water yield (see discussion of altered
water yields, this section) and increased
sedimentation. Although an increase in water yield
may be beneficial, the increase in suspended
solids would result in increased filtration costs.
Conclusions
Timber harvest would have very little effect
on water yield in the larger rivers and streams.
Sedimentation is expected to be greatest under
Alternative 1 and least under Alternative 8.
Increased stream temperatures can be expected in
Alternative 1. There would be 469 acres harvested
in municipal watersheds in 5 years. Overall
impacts are greatest in Alternative 1 and least in
Alternative 8.
Impacts on Vegetation
This section describes the impacts of
implementing a timber management plan on
vegetation. All impacts to wetland and aquatic
vegetation 3-7 shows the are expected to be
insignificant potential activity in those watersheds.
Table 3-7 Proposed Activities in
Municipal Watersheds Based on
the Sample Five-Year Timber Sale
Plan
Acres to be
Municipal Watershed
Sale Year
Harvested*
City of Canyonville
1985
118
City of Drain
1985
160
City of Riddle
1987
133
City of Riddle
1988
58
Similar harvests have occurred in each of these watersheds over
the past decade
66
The impacts of timber harvesting on municipal
watersheds would be increased for all alternatives
except 1. Under Alternative 1, wetlands would be
significantly impacted by harvesting operations.
Aquatic vegetation would be protected only to the
degree afforded streams under the Oregon Forest
Practices Act. This would be inconsistent with
Executive Orders 11988 and 11990.
Terrestrial Vegetation
Management treatments applied under each
alternative would impact the existing vegetation in
direct relation to the level of treatment shown in
Table 1-2. Impacts to riparian habitat are expected
to be insignificant under Alternatives 6, 8 and 9
(over 18,300 acres protected). However, under
Alternative 1", riparian habitat would be included in
adjacent areas scheduled for final harvest and
subsequent management treatments. Under
Alternatives 2, 3, 4 and 7, the modified area control
concept would provide for harvest in riparian areas
(along third order and larger streams) by
individual tree selection, shelterwood or clearcut
methods. Alternative 5 would provide protection
for 8,070 acres along third order and larger
streams. Areas adjacent to first and second order
streams would be harvested under all alternatives
except 8 (see Table C-4). The resulting impact
would be alteration of the riparian habitat in and
around those areas where harvesting operations
would occur. The degree of impact would range
from removal of the old growth component where
individual trees are removed to severe alterations
where clearcutting occurs.
Timber harvesting initiates plant succession by
creating openings in the forest canopy similar to
those created by natural disturbances. Different
cutting practices (i.e., clearcutting and single tree
selection methods) open the canopy to varying
degrees, thereby influencing the plant composition
and duration of the plant communities.
Clearcutting completely removes the forest
canopy, thereby allowing the establishment of the
first successional stage (grass/forb). Openings in
the canopy created by commercial thinning, and to
a lesser extent mortality salvage, could result in
insignificant growth increases of understory
vegetation.
Vegetation composition in the SYUs would change
according to the level of harvest proposed under
each alternative. When compared to the existing
forest profile, this change is notable by a shift of
acreage from one age class to another (i.e., old
growth to non-stocked or 0-7 year age group).
This acreage shift is best shown by a percent
change in individual age class stratification as
shown in Table 3-8. Long-term effects (first,
second, fifth and tenth decades) were projected
and are displayed in Appendices E and F.
The full scope of potential benefits that might
accrue from old growth retention is yet unknown.
Maintaining a representative structural component
of old growth Douglas-fir across a range of
environmental variables until these processes are
better understood may be essential to maintaining
the long-term productivity of timber stands.
Yarding practices to be employed during the 10-
year period consist of ground or partial
suspension cable systems, cable with full
suspension and tractor systems. Each system
Table 3-8 Approximate Acres of BLM-Administered Timber Lands and Percent
of Change after One Decade
Habitat Age
Current
Acres
Alt. 1
Max. Tbr.
Alt. 2
Emp. Tbr.
Alt. 3
Lo MHS
Alt. 4
OPA
Alt. 5
No
Action
Alt. 6
HD
Alt. 7
No Herb.
Alt. 8
Full Eco.
Alt. 9
NPA
Grass/Forb
Non-stocked and
0-7 Years
34,143
54,957
+61%
50.359
+47%
48,293
+ 41%
46,930
37%
29,164
-15%
34,066
<-1%
32.163
-6%
15.212
-55%
46.741
+ 37%
Brush/Seedling
8-15 Years
40,853
42,399
+ 4%
41,636
+2%
41,446
+ 1%
41,205
+ 1%
42,621
+ 4%
39.204
-4%
38,773
-5%
36,421
-11%
41,100
< 1 %
Pole Sapling
16-45 Years
56,393
91.329
+62%
91.329
+62%
91,329
+ 62%
91,329
+62%
114,097
-102%
91,329
+62%
91.329
+62%
91.329
+62%
91.329
-62%
Young 2nd Growth
46-115 Years
82,176
71.010
-14%
71,033
-14%
71,048
-14%
71,054
-14%
89,141
8%
71,126
-13%
71.120
-13%
70.538
-14%
71,052
-14%
Mature
116-195 Years
79,807
74.503
-7%
75,736
-5%
76.242
-4%
76.614
-4%
89,885
- 1 3%
79.645
80.418
1%
85.171
-7%
76.291
-4%
Old Growth
196+ Years
1 10,864
66,527
-40%
70,640
-36%
72.378
-35%
73.604
-34%
34.996
-68%
85,751
-23%
87,623
-21%
103,196
-7%
74,378
-33%
These columns may not have the same total acres due to the differences in the land
especially true for Alternative 5, which also utilizes the 1972 land base and inventory
use allocations of each alternative. This is
Source: BLM allowable cut printout and district inventory.
67
impacts ground vegetation to different degrees
relative to the soil disturbance resulting from the
harvest system used.
Broadcast burning is the one method of slash
disposal proposed under each alternative. The
short- and long-term effects of burning are relative
to the severity of the burn. According to research
in the Coast Range of western Oregon (Morris
1970), 5.8 percent of the total area burned was
severely burned. While 16.6 percent of the area
remained unburned, 22.2 percent and 55.4 percent
received moderate and light burns, respectively.
The lighter burn provides a greater percent of
herbaceous and brush cover within the first 2
years after burning. Scheduled replanting of
coniferous seedlings in the area would contribute
to the alteration as a fire-induced plant community
became established. The study also showed that
natural restocking of coniferous species was
approximately 30 percent greater on burned, as
compared to unburned, sites in the first 4 years.
Coniferous seedlings raised in nurseries would be
planted (Table 1-2). Under the best possible site
conditions, rapid natural regeneration could occur
every 3 to 7 years, depending on seed crops.
Under artificial regeneration, seedlings are
generally planted the first year following harvest.
Because the planting stock is already two or more
years old, it can have a competitive advantage on
good sites and an even greater advantage on
poorer sites. Therefore, planting shortens the
amount of time required for succession to
progress beyond the grass/forb and
shrub/seedling stages. The major long-term
impact associated with planting is that, by
increasing the competitive advantage of Douglas-
fir, early successional stages are more quickly
passed through, and Douglas-fir attains site
dominance more rapidly. This acceleration not
only reduces the residence time of early
successional stages but also precludes the
development of maximum plant diversity. Planting
an estimated 15,200 acres with genetically
improved trees during the 10-year period would
not have a significant effect on the natural gene
pool in either the short or long term. No significant
adverse long-term impacts are anticipated with the
eventual planting of genetically improved trees on
90 percent of the intensive timber production base
for each alternative. Maintaining a broad selection
of parent trees would ensure variability in genetic
base populations. The artificial regeneration
program on BLM-administered lands is not
expected to significantly affect the stand or
species composition of the entire Roseburg Area.
(BLM administers 29 percent of the total forested
lands. Compare Appendices E and F.)
Herbicides are used to manipulate the species
composition, size, density, vigor and presence of
vegetation. Plant habitat altered by herbicides
would increase over that in the past decade in all
alternatives except 7 and 8. Applications are
targeted to control grass and broadleaf species to
provide a competitive advantage for conifers.
Because different herbicides work best for
selected target species, herbicides are often used
in combinations. In forestry applications, the
desired effect is acceleration of plant succession
from early successional stages to later stages
dominated by conifers. Gratkowski and
Lauterback (1974) reported on the height growth
of young Douglas-fir for a 5-year period after
release. Percentage increase in height growth over
non-released trees varied from 130 percent (for
trees one foot high when spraying occurred) to
149 percent (for trees six feet high) for basal spray
plots and from 255 percent (for trees one foot
high) to 171 percent (for trees six feet high) for
aerial spray locations.
Non-target vegetation immediately adjacent to
spray units may be affected by the movement of
herbicides through the air. Such impacts are
limited, but not eliminated entirely, by buffer strips
and by application techniques (Gratkowski 1974).
Although the direct vegetational impacts of
herbicide application are short term, the effects of
accelerating the establishment of conifer stands
are long term. Once the coniferous stands become
dominant they remain until the trees are harvested
or until natural disasters remove them. For greater
detail on herbicides and the provisions for
monitoring of herbicide application, see the FEIS
Vegetation Management with Herbicides: Western
Oregon - 1978 through 1987 (USDI, BLM 1978).
Some timber stands would be fertilized under all
alternatives except 5, 7 and 8. This practice would
result in immediate increases of nutrient
availability for all vegetation on the site. However,
resultant increased vigor and growth are directed
at commercial conifer species. These are short-
term impacts lasting for an average of 7 years,
depending on site quality.
Sensitive, Threatened or
Endangered Plants
Unidentified populations of sensitive,
threatened or endangered plant species could be
susceptible to any impacts described under
terrestrial vegetation. The direct effects of injury or
death to the plants could cause the immediate
elimination of a species in all or a significant
portion of its range. The more subtle effects of
vegetative community changes could cause the
eventual elimination of a species locally through
loss of competitive ability relative to other
vegetation on the site.
If any species of vascular plant is determined by
the U.S. Fish and Wildlife Service to be threatened
or endangered, any action that contributes to its
extinction or to its threatened or endangered
status would be in violation of the Endangered
68
Species Act of 1973 as amended. Therefore,
environmental analysis accomplished prior to any
site specific action would include any threatened
or endangered plant species known to be present
on the site and appropriate measures to be taken.
Conclusions
Alterations to plant community structure and
longevity would be the most significant impacts to
terrestrial vegetation on those lands included in
the timber production base. Continued timber
management would not allow natural succession
to replace these communities because future
forests would be harvested before they reached
the 90-year age class.
Ecosystem management assumes that every
component of a naturally functioning system
serves a purpose and that each component
benefits the system. At the present time, there is
no definitive description of the functioning of the
old growth system and its importance to long-
range timber production.
The symbiotic relationships between plants and
animals that function in old growth stands are not
fully understood and may prove to be important to
long-term timber production. Until this is
understood, maintaining a representative range of
the old growth forest and associated floral and
faunal genotypes is important. All alternatives
would to provide an adequate representation of
the original old growth systems over the short
term.
The short-term use of the commercial forest lands
for timber harvest would increase the long-term
production of wood fiber as old, slow-growing
stands are replaced by young, fast-growing stands
managed for optimum wood production. In the
long term, as the area approaches a balance of age
classes, maximum growth of commercial
coniferous species is achieved.
Changes in plant communities and habitat could
eliminate some plant species over the long term.
Intensive timber management practices such as
planting and herbicide application would favor
survival of coniferous trees. However, elimination
of hardwood trees, shrubs and herbaceous
vegetation would not occur.
An additional type of impact involves the
management option of using a lower minimum
harvest size (MHS). A significant trade off between
short-term use and long-term productivity exists.
Alternative 3 differs from 4 in that it utilizes a lower
MHS (see Chapter 1). Over the short term (the first
10 years), Alternative 3 would allow harvest of 70
MM bd. ft. (7 MM bd. ft./year) above that of
Alternative 4. However, over the long term, total
productivity would be less. Maximum growth and
yield are attained when a regulated forest is
achieved, producing an estimated annual harvest
of 303 MM bd. ft. on the timber production base of
Alternative 4. Alternative 3 would have an annual
harvest higher than Alternative 4 until
approximately the 13th decade, when Alternative 4
achieves regulation. During this time, a total
harvest of 910 MM bd. ft. above the Alternative 4
level would be realized. Beginning in the 13th
decade, Alternative 4 would produce the higher
annual harvest (303 MM bd. ft. at the regulation
level) until Alternative 3 achieves regulation in
approximately the 30th decade. During those 17
decades, Alternative 4 would produce an
additional 7,990 MM bd. ft. for harvest. Therefore,
over the long term (at least 30 decades into the
future), Alternative 4 would produce 7,080 MM bd.
ft. more than Alternative 3. A similar relationship
would exist for all alternatives which utilize a 50
year minimum harvest age.
Existing older forest communities scheduled for
final harvest would be converted to early
successional stage communities. This impact is
unavoidable. Table 3-9 indicates the amount of old
growth habitat that would be irretrievably lost as
long as those acres are managed intensively for
timber production under all Alternatives except 8.
Permanent new road construction ranging from
1 ,662 acres in Alternative 8 to 5,568 acres under
Alternative 1 would result in the unavoidable
elimination of vegetation on these acres.
Impacts on Animals
Timber operations impact both animals and
their habitats. In most cases, the greatest and
longest-term impacts occur on animal habitats,
rather than on individual animals. Thomas (1979),
Meslow (1977) and Wight (1974) have shown that
certain species of vertebrates are associated with
forests that are of a particular age class and
resulting structure. Some species habitat
requirements are rigid, others are more flexible.
Appendix D lists species occurring in the SYUs
and their association with various habitats.
The predicted structure of habitat on BLM-
administered forest lands (Appendix E) was
calculated using the allowable cut runs and district
inventory data. In an attempt to place BLM plans in
perspective, the predicted structure of habitat in
the entire EIS area (as defined in Chapter 2,
Animals) was also estimated by applying
extremely rough projections of harvest levels (by
ownership) on all these lands over the first 10
decades (see Appendix F).
Terrestrial Vertebrates
Transportation System
Road construction would eliminate vegetation
from the roadbed. The acreage would vary (see
Table 1-2) depending on the alternative selected.
Currently about 12,000 acres have been cleared for
roads. The added impacts of habitat elimination
would be adverse and perpetual since most road
69
Table 3-9 Acres of Old Growth* (196+
) and Percent Change from Existing
on BLM-Administered Lands Remain
ing at the End of Each Decade
(Current: 110,900
acres)
Alt. 1
Alt. 2 Alt. 3
Decade
Max. Tbr.
Emp. Tbr. Lo MHS
1
66,500 (-40%)
70,600 (-36%) 72,400 (-35%)
2
28,700 (-74%)
36,300 (-67%) 40,900 (-43%)
3
8,600 (-92%)
16,600 (-85%) 28,400 (-74%)
4
8,700 (-92%)
16,400 (-85%) 27,800 (-75%)
5
8,900 (-92%)
16,600 (-85%) 27,900 (-75%)
6
9,000 (-92%)
16,100 (-85%) 26,800 (-76%)
7
9,000 (-92%)
15,700 (-86%) 25,800 (-77%)
8
13,500 (-88%)
20,500 (-82%) 31 ,300 (-72%)
9
13,600 (-88%)
21,000 (-81%) 31,800 (-71%)
10
13,700 (-88%)
21,100 (-81%) 31,800 (-71%)
Alt. 4
Alt. 5 Alt. 6
Decade
OPA
No Action HD
1
73,600 (-34%)
35,000 (-68%) 85,800 (-23%)
2
42,400 (-62%)
13,000 (-88%) 66,500 (-40%)
3
28,400 (-74%)
4,800 (-96%) 59,300 (-47%)
4
27,800 (-75%)
5,000 (-95%) 57,800 (-48%)
5
27,900 (-75%)
5,400 (-95%) 58,200 (-48%)
6
26,800 (-76%)
5,500 (-95%) 55,800 (-50%)
7
25,800 (-77%)
5,600 (-95%) . 54,600 (-51%)
8
31,300 (-72%)
6,300 (-94%) 62,700 (-43%)
9
31,800 (-71%)
6,800 (-94%) 66,100 (-40%)
10
31,800 (-71%)
7,300 (-93%) 68,100 (-39%)
Alt. 7
Alt. 8 Alt. 9
Decade
No Herb.
Full Eco. NPA
1
87,600 (-21%)
103,200 (-7%) 74,400 (-33%)
2
71,400 (-36%)
106,100 (-4%) 42,800 (-61%)
3
53,600 (-52%)
105,000 (-5%) 31,000 (-72%)
4
53,900 (-51%)
103,600 (-7%) 31,000 (-72%)
5
56,200 (-49%)
106,000 (-4%) 31,800 (-71%)
6
55,800 (-50%)
1 02,400 (-8%) 31 ,300 (-72%)
7
55,400 (-50%)
101,100 (-9%) 30,800 (-72%)
8
63,700 (-43%)
1 13,500 (+2%) 37,000 (-67%)
9
67,500 (-39%)
119,500 (+8%) 38,200 (-66%)
10
70,000 (-37%)
123,500 (+11%) 38,900 (-65%)
* Rounded to nearest 100 acres
Source: BLM allowable cut printout and district inventory.
systems would be maintained indefinitely.
Increased mortality due to collisions with vehicles
is unpredictable but probably insignificant.
Harassment of wildlife by vehicles undoubtedly
would occur and during stress situations, such as
times of temperature extremes, would adversely
affect the animal's physiological mechanisms and
mortality could occur. Losses to this cause would
not be expected to be large or significant to the
population as a whole. New miles of roads mean
more access by hunters and increased harvest and
harassment is probable. Legal harvest can be
limited by regulations adopted by the Oregon Fish
and Wildlife Commission but an increase in
poaching is probable. This could lead to
depressed deer and elk populations in local areas.
Lyon (1979) and Perry and Overly (1977) have
shown that elk use is reduced within one-half mile
of roads traversing elk habitat. This reduced use
varies with terrain, cover, distance and other
factors, so an accurate quantification is possible
only on a site specific basis. However, the
70
probable effects of a mile of road through elk
habitat can be described in general terms.
Vehicular use of a road will affect elk use of the
adjacent habitat. This influence on use may extend
for at least 660 feet on either side of the road, thus
affecting an area of 160 acres per mile of road. It is
estimated that elk use of this 160 acres may be as
much as 75 percent less than that of similar habitat
not influenced by road use. Such a reduction in
habitat use must be considered adverse. Effects of
roads on deer are "variable and relatively
insignificant" (Perry and Overly 1977, page 34).
All alternatives contain provisions to close some
roads in order to reduce harassment and
poaching. Past experience has shown these
closures difficult to enforce. Once roads are
effectively closed, elk use increases to near normal
levels. In the Tyee area planned road closures
should improve elk use of habitat adjacent to
roads.
Timber Harvest
The greatest effect timber harvest would
have on terrestrial vertebrates during the first
decade would be the modification of habitat by
clearcutting. The amounts range from 66,780 acres
in Alternative 1 to 19,915 acres in Alternative 8 (see
Table 1-2). The removal of mature and old growth
stands eliminates the habitat of those species of
animals adapted to exist there. If similar
unoccupied habitat exists nearby, then those
displaced individuals could occupy them. It is
unlikely that such a situation exists as it is
assumed that habitats are currently at carrying
capacity.
For certain species (e.g. elk, deer, spotted owls
and other cavity dwellers) which are influenced by
habitat availability and arrangement, efforts will be
made during the first decade to schedule the
harvest of mature and old-growth forest to benefit
these species or to minimize adverse impacts.
In the short term, all alternatives except 5 would
have at least 65,000 acres of old growth forest
remaining. Although the arrangement of this
acreage may not be optimum for all species, there
would likely be sufficient habitat after one decade
of management to retain a representative
ecosystem.
In Alternatives 3, 4 and 7, approximately 52,000
acres (Table 1-3) are proposed for modified area
control management, and with the exception of
riparian zone habitat on third order and larger
streams, the lands are confined to corridors. (The
riparian zones are scattered across the district.)
Mature and old growth forests, a necessary
element of habitat diversity, would be located in
these corridors. These also are the lands that
would provide the major portion of the snags for
cavity dwellers, northern spotted owl habitat,
survival cover for elk and ties to other corridors.
For Alternatives 2 and 9 the same issues are
applicable, but the land area proposed for
management is 24,800 and 35,900 acres,
respectively. In Alternative 9 no harvest is planned
from riparian zones on third order and larger
streams.
Currently there are about 110,900 acres of old
growth (196+ years) on BLM-administered timber
lands in the SYUs (Table 3-8). If Alternative 8 were
selected, old growth would increase over time and
have a beneficial impact on species using this
habitat (Table 3-8 and Appendix E). However, if
any other alternative were chosen, old growth on
BLM-administered land would decrease over time.
The decreases range from 37 percent in
Alternative 7 to 93 percent in Alternative 5 (see
Table 3-9 and Appendix E). Related decreases in
animals (see Appendix D) that find their optimum
habitats in these stages would be probable.
Examples are the big brown bat, northern flying
squirrel and pileated woodpecker. The actual
viable old growth habitat is less than appears in
Appendix E because a portion of the remaining old
growth would be in riparian zones that, because of
their long, narrow configuration, would not have
true old growth habitat characteristics. In the long
term, enough mature and old growth habitat would
be provided by Alternatives 6 through 8 to assure
maintenance of viable populations of animals
dependent on these habitats. Alternatives 1
through 5 and 9 would not do this.
When habitat structure on all lands in the EIS area
(see Chapter 2, Animals) is examined (Appendix
F), old growth would decline in all alternatives. In
the long term, all old growth timber remaining in
the EIS area would be on Federal lands
administered by BLM and U.S. Forest Service.
With this reduction of old growth habitat, a related
reduction of old growth dwelling populations
would be probable (see Appendix D).
The Tyee area is the most important elk area in the
Roseburg SYUs. In total it comprises about 5
percent of the State's Tioga Wildlife Management
Unit, which has historically produced the majority
of the elk harvested in southwest Oregon.
Planned timber management activities in the Tyee
area would change existing habitat conditions and
influence elk populations as shown in Table 3-10.
In the short term elk populations would increase in
the Tyee area under all alternatives as a result of
increased forage produced by clearcut harvest,
provided that vehicle access does not lead to
increases in harassment and poaching. Planned
road closures should help reduce such problems.
For all alternatives the population would peak in
the second decade, then decline to a level similar
to that which presently exists by the end of the
second decade. In the long term, 30 to 50 years
hence, a gradual decline from second decade
levels is expected for all alternatives except 8. The
71
Table 3-10 Estimated Elk Population
Changes on BLM-Administered
Lands in the Tyee Area 1
Alternative
2nd Decade
5th Decade
10th Decade
1
2
3
4
5
6
7
8
9
No change
No change
No change
No change
No change
No change
No change
No change
No change
-25%
-25%
-25%
-25%
-10%
-5%
-20%
No change
-25%
-25%
-20%
-30%
-20%
-20%
-5%
-20%
No change
-20%
1 All values ±5 percent
Source: BLM District and State Office personnel
estimated elk population 50 to 100 years in the
future is expected to be 20 to 30 percent less than
present levels for Alternatives 1 through 5, 7 and 9.
Alternative 6 is expected to show a 5 percent
decline, while Alternative 8 no change.
Because of its importance to elk, the Tyee area has
certain management prescription designs to
benefit elk in Alternatives 3, 4, 7 and 9. They
include: 30 to 40 percent of clearcut area
consisting of smaller (15-20 acre) clearcuts and of
a shape which maximizes edge habitat; a distance
to cover not to exceed 500 feet within those
clearcut units; and a minimum cover width
adjacent to units of 200 feet. These design features
along with planned road closures would benefit
deer and elk and help reduce long-term adverse
impacts in this area.
Decreases in mature habitat (116-195 years old)
would occur in all alternatives. The decreases
would have an adverse impact upon the animal
populations occurring there.
In Alternatives 1 through 7 and 9, increases occur
in pole/sapling and young second growth and
associated animal populations would have
corresponding changes (see Appendices E and F).
Early successional stages (1-15 years) following
harvest would benefit some species. The savannah
sparrow, brush rabbit, mountain beaver, deer, elk
and mountain quail are examples of species that
use early successional stages. There are currently
some 75,000 acres of early serai stage (less than
15 years old) vegetation on BLM-administered
timber land and an additional 370,000 acres of like
habitat on other ownerships within the SYUs.
Since this stage presently comprises about 30
percent of the total land base and will continue as
such in the future, there would be adequate levels
in both the short and long term to meet the habitat
needs of species associated with these
successional stages.
In future decades, except for Alternative 8,
clearcutting acreage would decrease while
commercial thinning dramatically increases.
Commercial thinning would occur in the
pole/sapling and young second growth that
account for the majority of habitat remaining at the
end of 10 decades (see Table 1-2 for acreage to be
thinned during the first decade).
Commercial thinning removes up to 40 percent of
the basal area of the forest and has several effects
on wildlife habitat. The structure of the forest
becomes more simplified and animal species
diversity decreases. The stand is opened up and its
value as thermal cover is reduced (Edgerton and
McConnell 1976). Hiding cover is also reduced and
forage may not increase, for as Edgerton (1972)
pointed out, deer and elk use is less in partial cut
areas (30 percent basal area removed) than in
either clearcuts or unlogged stands. These
alterations resulting from commercial thinning
would result in lowered deer and elk populations
in comparison to present day clearcut
prescriptions.
Forest birds would be affected. As Franzreb and
Ohmart (1978) show, thinning decreases habitat
value for birds that forage by searching in the tree
foliage or gleaning in timber. Species such as red-
breasted nuthatch and golden-crowned kinglets
would be reduced, while ground feeders such as
the robin and house wren would increase.
Cooper's and sharp-shinned hawks use dense
second-growth Douglas-fir as their primary
nesting habitat (Reynolds 1971). The quality and
quantity of this habitat would be reduced by
commercial thinning.
Commercial thinning is not expected to result in
any significant adverse effects on wildlife in the
short term because of the small proportion of the
land base scheduled for treatment.
The skidding of logs during yarding destroys low
vegetation and compacts the soil. The complete
but temporary destruction of surface vegetation
due to yarding (see Table 3-2) would reduce the
amount of habitat for small rodents and
insectivores. Ground disturbances that do not
remove excessive topsoil may benefit local wildlife
populations such as elk and deer, seed-eating
birds and certain rodents that depend on early
sucessional communities. Swanson (1970, cited in
Bunnell and Eastman 1976) reported significantly
higher elk use on moderately or heavily disturbed
sites than on lightly disturbed sites.
Snag-dependent wildlife such as woodpeckers and
other cavity dwellers would be adversely affected
due to snag removal during harvest operations.
Based on the work of Thomas (1979), three snags
of prescribed sizes per acre would provide for
72
maximum populations of primary excavators. To
manage primary excavators at the 60 percent level
(considered a safe level) requires about two snags
(of prescribed sizes) per acre. Most private lands
are not routinely managed for cavity users;
therefore, the habitat component maintained on
BLM-managed lands is crucial to the survival of
snag-dependent species. District surveys revealed
that snags and/or wildlife trees are being provided
at the rate of 0.1 per acre on recent harvest units.
Using the snag management components
displayed in Table C-4, Table 3-11 was developed
to describe expected long-term snag densities on
the BLM-administered land base.
As can be seen from the table, only Alternative 8
reaches the 60 percent management level,
although Alternatives 6 and 7 are close. To provide
maximum wildlife benefits, snags should approach
an even distribution throughout the land base.
Alternative 8 is the only one that approaches even
distribution.
During the first decade, impacts would be minimal
because of the large amount of unharvested land
in the SYUs. However, for all alternatives except 6,
7 and 8, snag dwelling species would decline to
below BLM target levels in the long term (see
Table 3-11). This would be a significant adverse
impact as populations would fall below self-
sustaining levels.
New snags are created by natural mortality in the
forest. All alternatives except Alternative 8 would
employ some amount of mortality salvage during
the decade (see Table 1-2). The number of trees
per acre, their age and size are variable and not
predictable. While in general the impacts would
not be immediately significant, these trees are the
snags and down forage logs of the near future and
removing them eliminates potential and needed
habitats.
Riparian habitat is important as 88 percent of the
terrestrial wildlife species in the area use it to
some degree. The importance of this habitat is the
result of many factors, including cover, food,
water, edge and microclimate. The maintenance of
its values depends on sustaining the structural
integrity of the vegetation. Any alteration of its
structure decreases its value to terrestrial wildlife.
For most riparian areas, best management for
wildlife means no entry.
Table C-4 shows how each alternative treats
riparian zones. Alternative 8 is the only alternative
which provides any protection to small first and
second order streams unless they occur in an area
under other forms of management in the
constrained timber base. Approximately 12,150
acres of this habitat (first and second order
streams) would be modified and replaced by
younger vegetation if any alternative except
Alternative 8 were selected. Riparian habitat next
to first and second order streams is more like
adjacent upland habitat and its loss is not as
important as the loss of riparian habitat on higher
order streams.
Riparian vegetation on third order and larger
streams would undergo some planned harvest in
all alternatives except Alternatives 6, 8 and 9.
Alternative 1 would substantially alter riparian
habitat and the impacts would be significantly
adverse. Management by modified area control as
proposed in Alternatives 2, 3, 4 and 7 would also
Table 3-11 Long-Term Snag Density
Alt.
Snag/ac
Percent
Management
Level
1
0.13
<10
2
0.32
10
3
0.77
20-30
4
0.77
20-30
5
0.21
<10
6
1.43
40-50
7
1.25
40-50
8
2.24
70-80
9
0.77
20-30
Snag Distribution
Would not occur on 96% of land base;
adequate on 4% of land base
Would not occur on 89% of land base;
adequate on 11% of land base
Inadequate occurrence on 82% of land base;
adequate on 18% of land base
Inadequate occurrence on 82% of land base;
adequate on 18% of land base
Would not occur on 93% of land base;
adequate on 7% of land base
Would not occur on 47% of land base;
adequate on 53% of land base
Inadequate occurrence on 65% of land base;
adequate on 35% of land base
Would not occur on 25% of land base;
adequate on 75% of land base
Inadequate occurrence on 82% of land base;
adequate on 18% of land base
73
alter riparian habitats on those acres entered. A
yearly average of 12 acres clearcut and 96 acres
partial cut of third order and larger riparian zones
would be expected. The significance of this
disturbance is amplified as "Habitat alteration [in
riparian habitats] will affect wildlife far more than
indicated by the proportion of the total area
disturbed" (Thomas 1979).
Food supplies for grazers and browsers are more
readily available in the early successional stages
as compared with other successional stages. Deer
and elk use would increase and peak six to eight
years following clearcutting (Harper 1969; Crouch
1974). However, the food supply may not be
utilized if sufficient hiding or escape cover is not
nearby. To.assure sufficient wildlife cover,
clearcuts should not exceed 40 acres. In the
sample five-year timber sale plan, 59 of the 953
sale units would exceed 40 acres in size. The size
ranges from 2 to 51 acres, but averages 27 acres.
Clearcut size is only part of the mechanism
necessary to provide cover near feeding areas. The
other is to allow regrowth to provide cover (about
10 years) prior to clearcutting on adjacent lands.
Without this timing, the forage created may not be
utilized as no cover is available. Alternatives 6 and
8 provide for 10- and 15-year intervals respectively,
between adjacent clearcut units, and all other
alternatives provide for at least 3- to 5-year
intervals. As part of harvest scheduling design
features, a 10-year interval would be applied to all
lands under Alternative 9, where possible during
the first decade, so long as it did not limit the
ability to meet the prescribed allowable cut.
Should conflicts arise between the 10-year spacing
standard and meeting the allowable cut level, the
interval would be lowered. Such design features
serve to distribute harvest units, mitigating adverse
impacts to species which utilize mature and old-
growth forest habitat.
Other Timber Management
Treatments
Other treatments (Table 1-2) alter animal
habitat through vegetative manipulation.
Slash burning would eliminate most live vegetation
from the site and 80 to 90 percent of the
combustible material less than three inches in
diameter would be consumed. Larger material is
generally charred in place. Table 1-2 lists acres to
be burned for all alternatives. These effects vary
with the intensity of the burn, but immediate
impacts would be removal of vegetation and on
site reduction of associated animal populations.
This would last less than one growing season,
after which a vigorous growth of grasses and forbs
would appear and animal populations adapted to
early successional stage vegetation would
increase.
The removal of woody material reduces
obstructions to deer (Crouch 1974). Other species
such as juncos and wrens use logging slash as
activity centers. Juncos declined when slash was
burned (Franzeb and Omart 1978). Charring of the
larger material removes bark and eliminates micro-
habitats for invertebrates that are an important
item in the food chain. In addition, the resulting
habitats lack structure that slash provided and are
more simplified.
Harper (1969) reported higher Roosevelt elk use
on logging sites that had been burned than on
those that had not been burned, and explains that
on burned sites grasses were more than three
times as abundant. Grasses are a preferred food
item of elk. He warned, however, that slash
burning would not necessarily increase forage and
subsequent elk use on all sites as physical
characteristics make each site different in its
response to burning. Also, Crouch (1974)
indicated that slash burning increased the food
supply for black-tailed deer. In the Roseburg SYUs
grasses are commonly found in the early serai
stage plant communities. Some clearcut units
throughout the district are dominated by grasses.
This includes clearcuts in the Tyee area, the
primary elk use area.
Mechanical piling of slash would cause soil
disturbance and have impacts similar to those
caused by yarding. Piling removes downed slash
that may cause barriers to large ungulates.
Subsequent burning removes these barriers and
enough debris may be left to provide habitat for
some birds and small mammals.
All alternatives except Alternative 7 call for
herbicide use in site preparation and conifer
release during the decade. The impacts from all
alternatives except Alternative 7 are the same, only
the magnitude changes. (See Table 1-2 for acres
treated.)
There are four major types of impacts to animals
that could be associated with silvicultural
herbicide application: exposure to acute toxic
levels, exposure to chronic toxic levels, habitat
modification and carrier impacts. The following is
a brief discussion of these four impacts. Additional
information may be obtained from the final EIS on
herbicides (USDI, BLM 1978).
Newton and Norris (1968) sampled blacktail deer
taken from treated sites (2,4,5-T & Atrazine), and
were unable to detect residues in most tissues.
One animal was found to have a trace in the liver.
In a study by the manufacturer, goats given 0.2 mg
triclopyr/kg daily for 10 days were found to have
tissue residues above the detection limit of 0.003
ppm in only the liver (0.004 ppm) and kidney
(0.013 ppm).
74
According to Dost (1983), if an assumption of feed
intake by deer at 3 percent of body weight per day
is taken, at the hypothetical maximum of 400 ppm
of herbicide in browse, intake will be 30 grams
feed/kg or 12 mg herbicide/kg. In the goat study
the maximum concentration in muscle was
between zero and 0.003 ppm, and will be taken as
0.003 ppm. Studies in other species show that
tissue concentration is proportional to dose rate.
The proportional concentration in the animal's
muscle would be 0.18 ppm (0.18 mg/kg) and/0.24
ppm (0.24 mg/kg) and 0.78 ppm (0.78 mg/kg) in
the liver and kidney respectively. To acquire these
dosage levels, an animal would have to forage in
freshly treated areas for 10 consecutive days
providing there would be no chemical breakdown
or deterioration. Therefore, the potential for
wildlife to suffer acute or chronic toxic effects is
unlikely at proposed herbicide use rates (see
Tables 1-4 and 3-17).
Herbicides have pronounced impacts on wildlife
habitat. These impacts are brought about by
losses of habitat diversity and stratification
resulting from the temporary setback of certain
plants that are in competition with the desired
coniferous species. This would adversely impact
those animals that utilize the grass/forb and
shrub/seedling successional stages.
Diesel oil is sometimes used as a carrier for forest
herbicides. Data on the toxicity of diesel oil on
wildlife are limited; however, some work has been
done on the adverse effects on adult ducks
(Tucker and Crabtree 1970; Hartung 1966; Hartung
1965). It is unlikely that wild animals would
consume lethal amounts of the carrier because of
the dilution factors involved. It may, however,
adversely affect the palatability of the forage.
Other potential impacts include the coating of
eggs, thereby affecting their hatchability, and the
wetting of individuals, making them more
susceptible to other environmental stresses.
However, data are insufficient to predict the
impacts of diesel oil carrier on animals in the EIS
area.
Precommercial thinning, although it may open a
young forest canopy, generally does not benefit
deer and elk because the unremoved slash
impedes movements. The obstacle presented by
slash accumulations restricts deer and elk from
utilizing any forage increases which result from
the thinnings. Cover use is also restricted by slash
accumulations. Therefore, reduced deer and elk
use would occur on those acres precommercially
thinned (see Table 1-2). This condition could last
as long as two decades before decomposition
removed the obstacles.
Conversely, birds and small mammals may
increase their use of an area following
precommercial thinning. Slash accumulations
provide cover for them and any increases in forage
production can be utilized.
Fertilization increases the growth and palatability
of many plant species. These increases may be
utilized by wildlife which would be a short-term
positive impact.
Fish
Impacts of timber management on fish and
aquatic habitat fall into the broad categories of
increased accumulation of bottom sediments,
increased amounts of suspended sediments,
altered amounts of stream flow, introduction of
logging debris, change of water temperature,
destabilization of banks and channels and
reduction of instream structure.
The impacts from the nine alternatives differ
primarily in magnitude. These differences reflect
the acres of land treated and miles of road built.
For instance, Alternative 8 has the fewest miles
constructed, while Alternative 1 has the most miles
of road constructed. (See Table 1-2 for all
treatments.)
On lands administered by BLM in the SYUs, there
are approximately 270 miles of streams that
support cold water fish (see Table 2-11). Analysis
of the sample 5-year timber sale plan shows that
approximately 17 miles of stream that support cold
water fish pass through or are adjacent to 77
harvest units.
Aquatic invertebrates, which are important both as
food for fish and as indicators of stream quality,
can also be modified or destroyed by the same
factors that affect fish habitat. It is assumed that
impacts to most invertebrates would be similar to
those experienced by fish in localized areas.
Research by Erman et al. (1977) revealed that
when buffer strips of at least 30 meters (about 98
feet) width on each side were maintained, the
macro-invertebrate populations were
indistinguishable from those of unlogged stream.
Maintenance of buffers helps minimize stream
degradation. Since Alternative 1 has no provisions
for buffer strips except as provided by the Oregon
Forest Practices Act, stream productivity might be
adversely affected.
Chapter 3, Impacts on Water Resources, provides
data on expected amounts of sediments and water
that would reach the streams of the SYUs and
compares them to existing amounts. Many of the
analyses and conclusions appearing in this section
are based on those data.
Transportation System
The construction of roads can add greatly to
the sediment load of a river. In Alternatives 1, 2, 3,
4 and 9, road building during the decade would be
more than in the past decade; however,
sedimentation from road building would be
increased only in Alternatives 1 and 2 (see Table 3-
6). Analysis of the sample five-year timber sale
75
plan shows about three miles of road would be
built on fragile or unstable soils that are adjacent
to streams with fishery values. If sedimentation
increased, the impacts would be adversely
significant to localized areas. Downstream
sedimentation could occur and could have
significant effects.
In discussing impacts to the aquatic invertebrates,
Erman et al. (1977) suggest that repeated failure of
road crossings was the cause of disruption of the
stream biota, not the construction of road
crossings. Investigations in the vicinity of newly
installed culverts showed only a slight impact.
Three new roads identified in the sample five-year
timber sale plan would cross streams with fishery
values. All are on stable soils so only short-term
localized impacts are expected.
Timber Harvest
Timber harvest can have an adverse impact on
fish habitat by removing the riparian zone,
changing water yield and increasing
sedimentation.
Removing the riparian zone, including old growth
conifers, would increase the amount of fine
organic material, reduce the number and quality of
pools, reduce useable spawning gravels, reduce
macro-invertebrate production areas, destabilize
banks and channels, and increase water velocities.
Logging riparian zones would also increase
sedimentation of stream bottoms and change
temperature regimes by decreasing shade.
However, where some streamside vegetation is
retained, no change in temperature was observed
(Brown and Krygier 1970). Water temperatures
would not increase if Alternatives 2 through 9 were
selected. Alternative 1 makes no provision for
riparian buffers and water temperatures would be
expected to increase. These increases are not
quantifiable but impacts are expected to be
adverse.
Clearcutting increases water yield (see Impacts on
Water Resources), which could have a scouring
effect on stream bottoms, thereby removing gravel
and aquatic vegetation. Based on the analysis
described in Chapter 3, it is estimated that water
yield changes would have a negligible impact to
the SYUs as a whole.
Harvest and yarding could contribute considerable
sediment to local streams. Increases in bottom
sediments, according to Gibbons and Salo (1973),
cause the most damage of all factors affecting
aquatic life. The amount of sedimentation would
depend on the alternative selected. Alternatives 4,
6, 7, 8 and 9 would reduce sedimentation
compared to past activities, while Alternatives 1, 2
and 3 would result in an increase (see Table 3-6).
While changes in fish production cannot be
quantified, any increase in sediment would have
an adverse impact while decreases would be
beneficial.
Other Timber Management
Treatments
Burning, animal damage control, precommercial
thinning and fertilization are not expected to have
a significant impact on fish.
The chemicals proposed for use for vegetation
control and the levels of their application are not
expected to measurably affect aquatic vegetation.
Streamside vegetation that provides shade could
be altered in a worst case circumstance. Buffer
strips along streams should prevent this from
occurring. However, due to pilot error, some parts
of these buffer strips could receive applications,
and some detectable amounts could reach the
stream.
Toxic effects of herbicides on fish have been
documented in the laboratory (U.S. EPA 1977).
However, proposed field application rates would
be considerably less than the minimum lethal dose
for those species tested and toxic effects are not
expected. (See BLM's FEIS Vegetation
Management with Herbicides, Western Oregon
1978 through 1987, for more detailed information.)
It should be noted that long-term effects,
particularly under field conditions, are more
difficult to determine than are effects in short-term
laboratory tests. Also, Cameron and Anderson
(1977) felt that more study use was needed in
order to evaluate the impacts to aquatic plants and
animals under field conditions. However, Cameron
and Anderson's monitoring program in 1977 and
Anderson's monitoring in 1979 showed that
amounts of herbicides in streams did not exceed
EPA's "safe" level standards.
Threatened and Endangered
Animals
Threatened and endangered species receive
special attention under the terms of the
Endangered Species Act of 1973, as amended, and
BLM policies and guidelines. Known locations of
these species are managed and special
precautions taken to ensure their well-being. (See
Chapter 1, Forest Management Treatments and
Design Elements.) Because of their habitat
requirements and locations, no impacts are
expected to occur to the Columbian white-tailed
deer and the bald eagle.
Transportation System
Threatened or endangered species would
probably be affected only to the extent that road
construction could open previously inaccessible
areas. This impact cannot be quantified or
qualified. Where road construction may affect a
given species, special measures are taken to
prevent significant adverse impacts.
76
Timber Harvest
Habitat modifications caused by clearcutting
would have long-term adverse impacts on old
growth-dwelling species. The northern spotted
owl, a State-listed species, is dependent on old
growth closed-canopy forests and would be
greatly affected.
The original Oregon Endangered Species Task
Force management recommendations for each
pair of owls (in effect during the preparation of the
proposed MFP) called for total protection of a 300-
acre old growth core area (if available) and an
additional 900 acres to be managed such that at
least 50 percent of this acreage would occur as
stands of 30+ year-old forests. Based on these
recommendations, Alternatives 3, 4 and 7 would
protect habitat for 18 pairs in the long term.
Alternative 9 would provide habitat for 18 pairs
under the recommendations, plus an additional
pair by other allocation for a total of 19 pairs in the
long term. It is highly probable that at least 25
viable pairs would remain at the end of the first
decade as a result of land use allocations and
harvest scheduling. Alternative 6 would protect
habitat for 25 pairs, and Alternative 8, habitat for
55 pairs in the long term. Alternatives 1, 2 and 5
have no provisions to protect owls in either the
short or long term.
Examination of the sample five-year sale plan
reveals planned harvest units would involve the
habitat of 23 of the 55 known pairs. Consideration
will be given to scheduling harvest units to
eliminate or reduce adverse impacts.
A revision of Task Force recommendations has
resulted from recent data. The revision
recommends that forests be managed to provide
1,000 acres of old growth per pair of owls within a
1.5 mile radius of nest sites. Currently, 42 pairs
occupy habitat that meets this criterion. The
following analysis of the relationship of the
alternatives to spotted owl habitat is based on the
assumption that the revised recommendations
identify minimum essential habitat. Land use
allocations in Alternatives 6 and 8 would provide
enough habitat for 24 and 42 pairs respectively in
both the short and long term. None of the other
alternatives would provide habitat for any owls in
the long term. Because timber sale locations
beyond the five-year plan are not known, it is not
possible to predict when various pairs would have
their habitat removed.
Conclusions
With the exception of Alternative 8, both
short- and long-term reductions of old growth
would have an adverse impact on old growth
species. In the short term adequate habitat would
exist for viable population levels of old-growth
related species in all alternatives except 5. Short-
term habitat diversity will improve under all
alternatives as the serai stage mix is enhanced by
harvest and succession. Alternatives 1, 2 and 5
significantly reduce mature and old growth habitat
in the long term, and selection of one of these
alternatives would have significant adverse
impacts on old growth species and habitat
diversity. In the long term, intensive forest
practices in Alternatives 1, 2, 3, 4, 5 and 9 would
lead to even-aged stands that would significantly
reduce habitat diversity and adversely impact
wildlife.
Simplification of forest habitats would also have a
significant effect on wildlife. Pole, sapling and
young second growth (which would account for
most of the forests, except in Alternative 8) have
low environmental variables (simple structure)
even under natural conditions. Further loss of
structure from thinning would make these age
classes of very low value for most wildlife. Further
simplification resulting from broadcast burning
and herbicides would add to the loss of diversity.
This long-term simplification and loss of diversity
would be significant and adverse.
During the short term, snag-dependent wildlife
would decline but remain at viable levels.
Continued decline in the long term would reduce
populations below viable levels in Alternatives 1
through 5 and 9. This is a significant adverse
impact. Alternatives 6 and 7 would support
marginal populations while Alternative 8 would
provide for adequate numbers.
Riparian habitat occupies about 3 percent of the
forest land base and is used by 88 percent of the
terrestrial wildlife species. This crucial habitat
would be adequately protected through the
selection of Alternatives 6, 8 or 9. Selection of any
other alternative would result in varying degrees of
adverse impact to riparian habitat. Alternatives 1
and 5 would result in significant adverse impacts
to this habitat.
Habitat removed by road construction is assumed
to be permanently and irretrievably lost on those
roads proposed as part of the permanent road
system. The construction of new roads would lead
to harassment of wildlife and reduce useable elk
and large carnivore habitat within one-quarter mile
of these roads. Planned road closures, if effective,
would reduce this impact.
Deer numbers are not expected to be greatly
modified by any of the alternatives in the short
term, but once commercial thinning dominates the
harvest, beginning in the sixth decade, populations
may be reduced. Because of different
requirements, elk numbers would be influenced by
many of the alternatives. The changes would be
due to changing habitat conditions, new road
construction, thinning and other habitat modifiers.
No adverse impacts to elk are expected in the
short term. Elk populations would in fact increase,
77
peaking in the second decade. In the long term, 30
to 50 years hence, a gradual decline from second
decade levels is expected for all alternatives
except 8. The estimated population in 50 to 100
years is expected to be 20 to 30 percent less than
present levels for Alternatives 1 through 5, 7 and 9.
Alternative 6 is expected to show a 5 percent
decline, while Alternative 8 would result in no
change. In the long term projected declines in elk
production on Roseburg District lands may place
additional demands for elk production on other
federal lands including the Umpqua National
Forest, which adjoins the east boundary of the
Roseburg District.
If it is assumed current fish populations reflect
conditions and harvest regulations over the past
decade, then itcan be assumed that fish
populations would decline under Alternatives 1
through 3 due to increased sedimentation. Fish
would increase in Alternatives 4, 6, 7, 8 and 9 and
remain the same under Alternative 5. The
population changes cannot be quantified.
The northern spotted owl is the only species listed
by the State of Oregon as threatened that would
be adversely impacted. The original
recommendations of the Oregon Endangered
Species Task Force influenced the proposed
alternatives for the EIS area. Assuming that these
recommendations identify minimum essential
habitat, 18 of the 55 known owl pairs in the SYUs
would be fully protected in the long term by
Alternatives 3, 4 and 7, 19 pairs by Alternative 9, 25
pairs by Alternative 6, and 55 pairs by Alternative
8. A recent revision of the Task Force
recommendations indicates that minimum habitat
requirements may be greater. If so, Alternatives 6
and 8 would provide habitat for 24 and 42 pairs
respectively. No other alternative would support
any owls in the long term.
In all of western Oregon the combined BLM timber
management decision for Medford and Coos Bay
districts and the new preferred alternatives for the
Eugene, Roseburg and Salem districts would come
close to meeting the original Oregon Endangered
Species Task Force recommendation for
protection of the northern spotted owl. At the end
of the first decade it is expected that all western
Oregon BLM districts combined would maintain at
least 90 pairs of owls, resulting from allocations
made in land use plans and harvest scheduling.
Cumulative adverse impacts are expected to be
minimal in the short term. Habitat for an estimated
78 of the recommended 90 pairs would be
provided long-term protection through the land
use planning process. In the long term a BLM
shortfall in providing the recommended portion of
owl pairs may result in a significant adverse impact
to the species unless the unmet needs were
reapportioned by the Oregon Endangered Species
Task Force.
Impacts on Recreation
The impacts of timber management on
recreation are related to changes in the physical
setting. From the setting, recreationists derive
different satisfactions, experiences and benefits.
As changes in the setting affect experiences, levels
and patterns of visitor use change. For example, in
one area recreation use might be facilitated by
road construction. In another area, visitation may
show a long-term decline if the area's setting or
resource availability is significantly altered. Some
visitors may relocate to other areas where
opportunities for desired experiences exist.
Each alternative varies in approach and emphasis
on meeting recreational needs. Some localized
recreational demand would not be met if areas and
facilities are not provided. The provision of areas
and facilities for recreational pursuits would be
beneficial since opportunities would be available
to meet increasing demand (Chapter 2, Table
2-13).
As natural or natural-appearing environments are
altered due to timber harvest, opportunities related
to appreciation of the natural environment are
reduced. Opportunities for such activities as
camping, hiking, fishing, hunting, nature study and
sightseeing would be degraded in some areas. The
degree and magnitude of impact would be
dependent upon the level of intensive timber
management under each alternative.
The alternatives provide for varying degrees of
protection, use and maintenance of existing
recreation sites. Generally, Alternatives 1 and 5
have minimal or no provisions to preserve
opportunities for additional recreation site
development. Alternatives 2, 3, 4, 6, 7, 8 and 9
allow for the protection of recreation development
opportunities. Assuming these developments are
realized, these alternatives would adequately meet
increasing demand on public lands related to such
activities as camping, picnicking, hiking,
horseback riding, swimming and water-oriented
use (see Appendix C, Table C-4).
Clearcutting can enhance certain recreational
activities such as hunting, collecting, berry
picking, general sightseeing, picnicking and using
ORVs by creating areas, improving access or
providing openings for scenic views. The impacts
of clearcutting would be most significant under
Alternative 1 and moderately significant under
Alternatives 2, 3, 4, 7 and 9. Alternatives 5 and 6
call for levels of clearcutting similar to that under
the existing situation. Under Alternative 8,
clearcutting would be significantly less than under
the existing situation.
Many timber management activities create noise,
odors, dust, fumes and additional traffic. Some
recreational opportunities would be degraded by
78
these factors. However, many road-oriented
dispersed recreationists indicate that impacts of
timber management do not detract from their
enjoyment (Downing and Clark 1979).
Area-wide impacts to fishing and hunting success
are dependent upon impacts to the species (see
Impacts on Animals). In the short term, demand
for hunting (see Table 2-13) would be met under
all alternatives. In the long term, elk population
decreases under all alternatives except 6 and 8
(see Table 3-11) are expected to lead to decreased
elk hunting opportunities and a corresponding
reduction in hunter use. Declining fish populations
under Alternatives 1, 2, 3 and 5 are expected to
result in a similar reduction in fishing
opportunities and related angler use (see Impacts
to Animals, Conclusion). Decreased hunting and
fishing opportunities could result in a relocation of
these recreationists to other areas.
Vehicular access would be improved as a result of
new road construction. The beneficial and adverse
impacts on recreation would be most apparent
under Alternative 1 and least apparent under
Alternative 8.
Analysis of the sample 5-year timber sale plan
indicates that slight reductions or increases in
visitor use could occur at specific sites. Clearcut
units near Severt Iverson County Park, Berry
Creek Reservoir and Cavitt Creek County Park
may create slightly adverse visual and auditory
impacts which would degrade the recreation
experience for some facility users. Harvest units in
areas offering off-road vehicle opportunities
(Yellow Creek Mountain, Hubbard Creek,
Deadman Mountain) would not create significant
adverse impacts but could result in slight
increases in visitor use at these areas.
Timber harvest in the vicinity of potential hiking
and equestrian trails could degrade the recreation
experience for most future trail users but could
also provide clearings with scenic viewing
opportunities. Such impacts could occur along
potential trails in the following areas: Berry Creek,
Tyee, North Umpqua-south side, Old Fairview,
Silver Butte and White Rock.
Environmental assessments which precede each
timber sale will provide a site specific analysis of
these potential impacts identified during the
analysis of the sample timber sale plan.
Impacts to potential national wild, scenic or
recreational rivers will be further analyzed in the
environmental assessments which precede each
timber sale. If it is determined during site specific
analysis that timber management actions could
adversely affect potential suitability of those
sections of the Umpqua or North Umpqua Rivers
as components of the national wild and scenic
rivers system, BLM would consult with the
National Park Service to develop appropriate
mitigation measures. There are no clearcut units in
the sample 5-year timber sale plan within one-
quarter mile of these river sections.
Conclusions
Visitor use increases or reductions may
occur in certain areas as a result of impacts to
specific recreation experiences. Alternatives 1 and
5 would serve to adequately meet increasing
demand for motorized recreational vehicle use and
some dispersed use areas. However, under these
alternatives, demand associated with many other
activities (e.g., hunting, fishing, watersports and
developed site use) would not be met due to a loss
of development opportunities, degradation of the
desired recreation experience and effects on
recreation-related wildlife populations.
Alternatives 2, 3, 4, 6, 7, 8 and 9 would serve to
meet most recreational needs. In the long term,
however, elk population decreases under all
alternatives except 6 and 8 are expected to result
in lower hunting success and a corresponding
reduction in elk hunter use. Under Alternatives 1, 2
and 3, some fishing demand would not be met
because declining fish populations are expected to
result in a lower fishing success and some
decrease in related angler use. A lower desirability
of BLM-administered lands for fishing and elk
hunting could occur.
The focus of Alternatives 6 and 8 is on dispersed
activities, natural areas and protection of
developed site opportunities in some areas. As a
result, these alternatives would not be as
responsive as Alternatives 2, 3, 4, 7 and 9 in
meeting demand for hiking, horseback riding and
off-road vehicle areas and trails.
Impacts on Cultural
Resources
Complete area-wide field surveys of the SYUs
to identify cultural sites have not been undertaken.
However, complete cultural resource surveys will
precede each specific timber management action
that would result in ground disturbance or transfer
of title (BLM Manual 8100, Cultural Resource
Management). Under all alternatives, significant
sites identified during these surveys would be
protected in accordance with the National Historic
Preservation Act of 1966 and Executive Order
1 1593, as stated in the Code of Federal
Regulations (36 CFR Part 800).
Cultural resources not identified by intensive field
survey could be inadvertently impacted under all
alternatives. The potential for damage would be a
function of the alternative's timber harvest level.
Adverse impacts to such sites could occur through
soil compaction, soil movement and/or chemical
alteration by fire or mixing of organic matter. Soil
compaction and soil movement could damage
79
artifacts and disrupt the internal structure of
cultural deposits. If sites are uncovered, illegal
artifact collecting could occur. A site's chemical
alteration during slash disposal and site
preparation could destroy combustible items,
damage stone artifacts and contaminate carbon 14
dating samples, making them unreliable for
scientific analysis.
The potential for damage from timber
management activity to undiscovered sites would
be greatest under Alternative 1 and least under
Alternative 8. In a worst case, impacts would
completely obliterate a site's remains. The
potential for impacts would also be greater in
areas of relatively high site density (e.g., Cow
Creek, Camas Valley, Honey Creek-Susan Creek,
Little River-Wolf Creek, Myrtle Creek, South
Umpqua and White Rock-Dompier).
Road construction would provide additional
access to known cultural sites, resulting in
increased visitation. Vandalism, theft and site
erosion could result. Esthetic, recreational,
interpretive and educational qualities of the sites
could be degraded. Road construction and/or
timber removal on slopes above sites could result
in increased rates of erosion and soil slumpage
onto sites. These adverse impacts would be most
likely under Alternative 1 and least likely under
Alternative 8.
The landscape and vegetation surrounding a
cultural site may be impacted by timber harvesting
and road construction. Such impacts could reduce
the site's esthetic appeal for recreation,
interpretation and education. Impacts to the visual
settings of cultural sites would be most likely
under Alternative 1 and least likely under
Alternative 8. Analysis indicates that the potential
exists for visual setting impacts as a result of
timber sales proposed in the sample 5-year timber
sale plan. Site specific analyses of sales will be
included in the environmental assessments which
precede each timber management action. Should
potential impacts to a site's setting integrity be
identified, design art techniques and other
constraints may serve to mitigate adverse impacts.
Conclusions
Appropriate measures would be taken to
identify and protect cultural sites prior to ground-
disturbing activities under all alternatives.
Undiscovered cultural sites would be susceptible
to damage from artifact breakage or destruction,
displacement of materials and contamination of
organic matter. Once a site is found, however,
mitigation measures would be taken to minimize or
avoid future damage. Under all alternatives,
significant sites identified before logging would be
managed to protect scientific and/or interpretive
values.
Impacts on Visual
Resources
Most timber management practices disrupt the
land surface, change vegetative patterns, alter
species composition, and thereby create visible
contrasts (see Glossary) in the landscape.
Assessing contrast for a proposed activity can
indicate the severity of impact and help identify
mitigation measures to reduce the contrast and
meet VRM class objectives for an area (BLM
Manual 8440). Environmental assessments will
address site specific visual impacts and apply the
Bureau's contrast rating system (see Glossary) to
specific timber management actions. The severity
of an impact on visual resources depends on such
factors as landscape elements; location, number,
size and shape of clearcut units; location and
design of roads; yarding methods; amount and
treatment of debris; and success of vegetative
reestablishment in disturbed areas.
Visual resource management (VRM) classes
shown in Figure 2-3 were based on an inventory
and evaluation of the area's scenic quality,
sensitivity and distance zone (see Glossary).
During the land use planning process, VRM
classes as described in Chapter 2 may be changed
to resolve conflicts between visual and other
resources (BLM Manual 8411). Upgrading an
area's recommended VRM class would provide
adequate scenic value protection and result in
beneficial impacts. Downgrading VRM classes
increases the potential for adverse visual impacts.
As an example, an area in the affected
environment recommended as VRM Class II but
subsequently managed as Class III or IV would
receive less protection. Consequently, the long-
term effect of downgrading might be to lower
scenic quality in downgraded and adjacent areas
even though the Bureau's ability to affect an area's
overall scenic quality is often limited by
intermingled land ownership patterns (see Figure
1-1). In some cases the impacts of BLM timber
management activities would be consistent with
those on surrounding areas and would not create
significant contrasts, but could tend to compound
the degree of contrast by enlarging the scale of
modification.
Table 3-12 gives total acreage for each VRM class
by alternative. Under Alternative 8, visual resource
conditions (scenic quality) would improve.
Adverse visual impacts in highly scenic and
sensitive areas would not occur or would be
mitigated. Under Alternative 6, most highly scenic
and/or sensitive areas would be protected with
slight adverse impacts occurring along some
county roads, portions of the South Umpqua River,
Little River, Rock Creek and Cow Creek drainages
and public lands in the viewsheds of some rural
residential areas.
80
Table 3-12 VRM Classes by Acreage
VRM
Affected
Environment 1
ALTERNATIVE
Class
1
2,3,4,7,9
5
6
8
I
30
30
30
30
30
30
II
75,700
2,400
9,300
1,100
26,600
75,700
III
22,900
400
13,600
3,000
22,400
22,900
IV
325,370
421,170
401,070
419,870
374,970
325,370
Total
424,000
424,000
424,000
424,000
424,000
424,000
1 VRM class acreage as recommended through the visual resource inventory and evaluation of the existing environment (see Figure 2-3)
Table 3-13 Potential Impacts of the Sample
Five-Year Timber Sale Plan on
Visual Resources
Clearcut
Scenic
Sensitivity
Units
VRM Class 1 Area
Quality 2
Level 3
Within Area 4
II Olalla Creek
B
H
5
Olalla
B
H
1
Cow Creek Road to Peck
B
H
7
Riddle
C
H
7
Garden Valley/Lookingglass
B
H
6
Tenmile
B
H
2
Berry Creek Reservoir
A
H
4
Camas Valley
B
H
15
Highway 38 (Pass Creek to Safley)
B
H
3
Coles Valley
A
H
2
Main Umpqua River
A
H
5
Pleasant Valley and I-5
B
H
5
Divide to Scotts Valley
B
H
2
Putnam Valley
B
H
2
Canyonville to Azalea
B
H
7
Riddle-Cow Creek Valley
B
H
14
Milo to East Boundary
B
H
3
Milo to Days Creek
B
H
10
Canyonville to Days Creek
B
H
1
South Myrtle Creek Drainage
B
H
10
North Myrtle
B
H
5
Dole
B
H
6
Wolf Creek Falls
A
H
1
Red Pond
A
H
4
Little River
B
H
12
Glide
B
H
3
North Umpqua River, Rock Creek
to Boundary
A
H
5
Lower Rock Creek to Rock Creek
Campground
B
H
12
III Reston
B
M
4
Drain-Yoncalla
C
M
9
Elkhead
B
M
5
Windy Gap (Smith River Road)
B
M
3
Smith River
B
M
9
South Myrtle Creek Drinage
B
M
2
North Myrtle
B
M
3
Buckhorn Road
B
M
2
Cavitt Creek
B
M
12
Driver Valley
B
L
7
Camas Swale and East Sutherlin
C
M
5
Nonpareil
B
M
4
' Recommended VRM class based upon an inventory and evaluation of the existing environment (see Figure 2-3)
; Scenic quality (see Glossary) is keyed as A-high, B-moderate or C-low
3 Sensitivity levels (see Glossary) are keyed as H-high, M-moderate or L-low.
' All potential impacts listed would be in the FM-foreground/middleground distance zone (see Glossary)
81
Adverse visual impacts under Alternatives 2, 3, 4, 7
and 9 would be low to moderate. Many highly
scenic and/or sensitive areas would be protected.
Attempts would be made to mitigate adverse
impacts on all public lands. Protection would be
afforded all State of Oregon designated scenic
corridors (e.g., North Umpqua Highway 138,
segments of Highways 42, 227 and Interstate 5),
essential bald eagle habitat and recreation sites.
Under Alternative 7 the intensive timber
production base would be 72,128 acres less than
under Alternatives 3 and 4 and 99,388 acres less
than under Alternative 2. The withdrawal of this
acreage would result in a lower level of timber
harvest and consequently fewer impacts to visual
resources than under Alternatives 2, 3, 4 and 9.
Under Alternatives 1 and 5, adverse visual impacts
would be high. Some protection would be
provided for certain highly scenic and/or sensitive
areas, primarily essential bald eagle habitat and
existing recreation sites.
Table 3-13 summarizes the potential visual impacts
of the Original Proposed Action's sample 5-year
timber sale plan. The table identifies the number of
clearcut units in recommended VRM class II and
III areas. The potential for impacts would be
greatest in foreground-middleground areas with
high scenic quality and high sensitivity. Following
application of the contrast rating system,
necessary mitigation measures would be
identified. Depending upon VRM class objectives,
possible mitigation measures under all alternatives
except 1 include manipulating the size and shape
of clearcut units, partial cutting, longer harvest
cycles (see Table 1-3), screening with buffer strips,
hydromulching road cuts and fills, complete debris
disposal, replanting with a conifer mixture and
other special techniques. Visual resources along
some streams with high scenic quality and/or
sensitivity may be adversely impacted since all
alternatives except 6, 8 and 9 result in buffer entry
for some timber harvest (see Table 3-5 and
Appendix C, Table C-4).
The adverse visual impacts of herbicide use would
go unmitigated and would occur under all
alternatives except Alternative 7. In the short term,
vegetation sprayed with herbicides would create
highly visible contrasts. In the long term,
vegetative variety would be reduced as herbicides
encourage conifers at the expense of other
vegetation of high visual interest. Herbicides used
on tall broadleaf species (madrone, oak, alder)
cause long-term impacts of up to 20 years or until
the dead vegetation is over-topped. Under all
alternatives except 7 and 8, the impacts of
herbicide use would be greater than under the
existing situation (see Impacts on Vegetation).
Impacts on Areas of Critical
Environmental Concern
Area of Critical Environmental Concern
(ACEC) designation would improve management
focus and provide guidelines to help achieve
protection of important and relevant resource
values. The alternatives vary in levels of ACEC
designation. Some of the potential ACECs are also
designated or proposed for other protective
designation (see Table 2-14).
Under Alternatives 6 and 8, seven areas (3,100
acres) would be designated. Under Alternatives 2,
3, 4, 7 and 9, four areas (2,100 acres) are identified
for ACEC designation. Of the remaining three
areas, two are currently designated Research
Natural Areas (RNA) and one is proposed for RNA
designation. Alternative 1 calls for ACEC
designation in four areas (600 acres). Alternative 5
has no provision for designation of ACECs.
Table 3-14 identifies the level of ACEC designation
and potential impacts to each area by alternative.
Analysis of the sample 5-year timber sale plan
indicates no sales would adversely impact those
areas qualified for ACEC designation.
Impacts on Special Areas
Table 3-15 summarizes the potential impacts
to areas with values which may warrant their
designation as Research Natural Areas,
Outstanding Natural Areas or Environmental
Education Areas. Myrtle Island and Beatty Creek
are currently Research Natural Areas and would
not be adversely impacted under any alternative.
Alternative 1 allows for designation of those areas
which would not affect the commercial timber
production base of the SYUs. Alternatives 2, 3, 4, 7
and 9 allow for designation of those areas
identified as having significant natural values for
science, recreation or education. Alternative 5
provides no additional natural area designation.
Alternatives 6 and 8 emphasize the study and
designation of natural areas. However, some sites
(e.g., Red Pond, Dompier Creek Landslide) with
natural or environmental education values may be
adversely impacted if they are not designated or
do not receive other protective management.
Analysis of the sample 5-year timber sale plan
indicates that no areas with known or suspected
natural values would be impacted.
Impacts on Energy Use
Table 3-16 indicates the annual energy
investment required by alternative, as expressed in
British thermal units (Btu's - see Glossary).
82
Table 3-14 Potential Impacts to Areas Qualified for ACEC Designation
ALTERNATIVE
Area Qualified for
ACEC Designation
1. Brad's Creek
2. Golden Bar
3. North Umpqua River
4. Tater Hill
5. Myrtle Island RNA
6. Beatty Creek RNA
7. North Myrtle Creek
(Slideover)
Total ACEC Acreage by
Alternative
1
2,3,4,7,9
5
6,8
_
-
-
-
-
1
-
-
1
-
600
2,100
3,100
= No impact - = Adverse impact
' Area is proposed for Research Natural Area designation which would protect the area's significant resource values.
Table 3-15 Potential Impacts to Special Areas
Potential
Area
Designation 1
Tater Hill 2
RNA
North Myrtle Creek 2
RNA
(Slideover)
Woodruff Canyon Lands
RNA
Old Fairview
RNA
Little River Arch
ONA
Red Pond
EEA
Dompier Creek Landslide
ONA
ALTERNATIVE
2,3,4,7,9
-
= No impact - = Adverse impact
' Key for potential designation: RNA - Research Natural Area, ONA -Outstanding Natural Area, EEA - Environmental Education
Area.
7 Impacts to this area are further examined in the preceding section on Impacts to Areas of Critical Environmental Concern.
It is assumed that all energy consumed would be
in the form of fossil fuels or derivatives, and any
energy investment would constitute an
irretrievable reduction of world supplies of
petroleum-derived energy. The majority of energy
consumed is attributable to road development and
care and log production (all actions taken to
harvest trees and get logs to the mill).
If the 716 billion Btu's attributable to the New
Preferred Alternative were all expended in the form
of gasoline, it would equate to 5.7 million gallons
or about 0.4 percent of the 1.3 billion gallons of
gasoline consumed in Oregon in 1980. This energy
investment is insignificant if compared to the
projected 1980 Oregon total of 581 trillion Btu's
(Oregon Department of Energy 1980).
Impacts to Human Health
The possibility of human health being
impacted by the use of herbicides is related to the
toxicity of the herbicide, the likelihood of exposure
and resulting dosage received (Norris 1975). While
there are no chemicals that are non-toxic, a
substance of moderate or high toxicity may
represent no significant hazard if exposure is very
low, just as a relatively non-toxic agent may be
harmful if exposure is extensive and long term.
Herbicides proposed for use in the SYUs are given
in Table 1-4 and their toxicities and activities are
given in Table 3-17.
83
Table 3-16 Estimated Annual Energy Consumption
ALTERNATIVE
12 3 4 5 6 7
Energy Consumption
(Billion Btu's) 834 770 741 723 528 536 514
8
218
9
716
Table 3-17 Herbicide Toxicity
Common
Name
Acute Toxicity
LD 50 1 Commonly Used
(Rats) Term 2
Activity in
the Soil
No Effect
Level Dose
in (mg/Kg/day)
Tolerances for
Residues in or
on Foodstuffs
(40 CFR Part 180)
Asulam
(Asulox)
8,000 mg/kg
practically
non-toxic
short persistence—
half-life 6 to 14 days.
(not available)
100 ppb
Atrazine
3,080 mg/kg
slightly toxic
absorbed on muck
or clay — remains in
1 foot of soil.
200
(Reproductive 3 )
20-250 ppb
2,4-D
300-1,000
mg/kg
moderately toxic
to slightly toxic
leached in sandy
soils, breakdown
depends on microbial
activity.
20 (Reproductive)
20 (Teratogenic 4 )
100-500 ppb
Dalapon
(Dowpon)
7,570 mg/kg
(female)
9,330 mg/kg
(male)
practically non-
toxic
500 (Teratogenic)
leaches readily in
soil, breakdown rapid
and complete.
50-150
(Reproductive)
100-10,000 ppb
Fosamine
(Krenite)
24,400 mg/kg
relatively
harmless
rapid degradation-
very little movement.
60 (Reproductive)
600 (Teratogenic)
(non listed)
Glyphosate
(Roundup)
4,320-
4,900 mg/kg
slightly toxic
strong absorption-
very little or no
leaching.
30 (Reproductive)
30 (Teratogenic)
100-6,000 pbb
Hexazinone
(Velpar)
1,690 mg/kg
slightly toxic
half-life 2 to 6
months in silt loams.
60 (Reproductive)
300 (Teratogenic)
100-200 ppb
Picloram
(Tordon)
8,200 mg/kg
practically
non-toxic
sorption by organic
matter and clays,
may leach in sandy
soils.
80-150
(Reproductive)
1,000
(Teratogenic)
50-500 ppb
Triclopyr
(Garlon)
2,140-
2,830 mg/kg
slightly toxic
possible leaching,
half-life of 46 day.
30 (Reproductive)
200 (Teratogenic)
(non listed)
' LD 50 (Lethal Dose 50) is the dose of a substance that is fatal to 50 percent of the test animals. Also known as median lethal dose.
2 Moderately toxic is 50-500 mg/kg, slightly toxic is 500-5,000 mg/kg; practically non-toxic is 5,000-15,000 mg/kg; relatively
harmless is more than 15,000 mg/kg in a single oral dose to rats
3 The highest dosage level at which no effects have been observed in test animals including loss of skin, hair, reduced litter size, or
general lethal toxicity
4 Fetus malformations during development, not associated with genetic change.
84
In general, exposure of humans to herbicides can
occur in two ways: directly, by occupational
means, or indirectly by environmental means. The
number of persons that could be affected by
herbicide application in the EIS area is very small.
Planned application techniques have been shown
to effectively reduce or prevent spray from drifting
onto streams and water bodies. Posting of sprayed
areas should effectively minimize involuntary
exposure to forest users.
All herbicides proposed for use in the RSYUs are
registered with the Environmental Protection
Agency (EPA). Extensive studies of the absorption,
distribution, metabolism and excretion of
herbicides in animals have shown that herbicides
and their metabolites are rapidly eliminated from
tissues of most animals (including humans) and
thus do not accumulate to harmful levels
(Eligehausen et al. 1980, Lavy et al. 1982, Leng et
al. 1982, Nash et al. 1982, Newton and Norris 1968,
Norris et al. 1974, Sikka et al. 1977, and Wolfe
1976). There is no evidence of carcinogenic effects
for any of the herbicides listed in Table 3-17. With
respect to 2,4-D, Picloram, Glyphosate, Atrazine
and Fosamine, some additional direct data are
needed to assure certitude. The laboratory
dosages at which potential reproductive effects
have been detected or at which carcinogenic and
mutagenic effects have been sought are much
greater in concentration and duration than any
exposure that could occur in the forest as a result
of vegetation control treatments. Because of the
limited toxicity of the herbicides and the low
potential for exposure, the likelihood of an adverse
impact on human health is negligible.
Impacts on Socioeconomic
Conditions
The socioeconomic impacts are presented here
for two different bases as a means of
differentiating between the effects of potential
timber management programs on existing
socioeconomic conditions and their effects on the
conditions expected to occur if the current timber
management program were continued. The
program manager must know how future
conditions would be affected if the program were
changed. The public is generally most concerned
with how future conditions would differ from
existing conditions. The impacts are presented
mainly in table form, as changes measured from
the existing condition and as changes measured
from the no action condition— the condition
expected if the current program were continued.
The average 12-month harvest from the Roseburg
District from 1976 to 1980 was 187.5 MM bd. ft.
This recent experience is the baseline labeled the
existing condition. The no action alternative, 201
MM bd. ft. per year, is the level which would have
prevailed if the decadal allowable harvest (2,010
MM bd. ft.) had been sold and harvested in
constant annual increments. The average level of
actual sales for 1976-1980 was 197.1 MM bd. ft.
and for 1972-1975 was 208.9 MM bd. ft.
Table 3-18 shows projections representing average
local employment and earnings potential of timber
sales under all alternatives during the first decade
after implementation. Impacts on employment and
earnings would be phased in over a period of 2 or
3 years due to the customary time lag between
sale and harvest. Impacts on receipts distribution
would be delayed an additional year. The
projections represent the local employment and
earnings which would be realized if the annual
volume sold under each alternative is promptly
harvested and processed.
While it is anticipated that labor productivity will
increase in future years, leading to fewer jobs per
unit of primary timber processed (Wall and Oswald
1979). In order to simplify impact estimates, they
have not been adjusted to reflect productivity
changes. The effect of this simplification is to
overstate the impacts on employment and
earnings by about 10 percent in the short term,
and by greater amounts in the long term.
Tables 3-19 and 3-20 focus on the impacts each
alternative is projected to have on public revenue.
Recently, Roseburg District's timber sale program
has experienced wide swings in bid prices for
stumpage. For example, in FY 1981 the average
price of timber sold was $260 per M bd. ft.;
however, in FY 1982 the district recorded an
average sale price of $94 per M bd. ft. Given this
volatility, tables 3-19 and 3-20 array possible
impacts on public revenue against two baseline
harvest levels and two levels of receipts. If FY 1981
sale values are the average for period 1984 - 1993,
then average annual disbursements to O&C
counties from the SYUs are projected to range
from $36.2 million in Alternative 1 to $10.5 million
in Alternative 8 (Table 3-19). When compared to
the no action condition, Douglas County receipts
from the harvest of timber on O&C lands in the
Roseburg District could decline by $.5 million in
Alternative 1 or by as much as $2.5 million in
Alternative 8, if FY 1982 sales values are the
average for the next 10 years. The average annual
disbursement of severance tax receipts from
CBWR lands to seven tax districts in Douglas
County is projected to range from $122,100 in
Alternative 1 to $35,500 in Alternative 8, if FY 1981
sales conditions prevail. Again, compared to a
maintenance of the no action level, Alternative 1
would yield an average annual decline in
severance tax receipts of $7,200 while Alternative 8
would yield $38,500 less if the district only
averages $94 per M bd. ft. over the next decade.
Historically, the sale of timber on public domain
lands in the Roseburg District has accounted for
roughly 1 percent of the district's total receipts
from the sale of timber. Assuming that percentage
were maintained in all alternatives, Oregon's
85
Table 3-18 Short-Term Impacts Compared to No Action (and Existing)
Condition on Local Employment and Earnings Related to Timber Harvest
(Average annual amounts during first decade)
Timber
ndustry Employment (Jobs)
Total Employment (Jobs)
Total Earnings
(Millions ol 1977 dollars
Logging and
Processing
Forest
Management
Douglas County
Total for
Regional Economy
Dougt
is County
Total for
Regional Economy
Dough
s County
Total tor
Regional Economy
Douglas
County
No
Action
Existing
No
Action
Existing
No
Action
Existing
No
Action
Existing
Action
No
Existing
Action
No
Existing
Action
No
Existing
Alt 1 (Max Tbr )
Alt 2 (Emp Tbr )
Alt 3 (Low MHS)
Alt. 4 (OPA)
Alt 5 (No Action)
Alt 6 (HD)
Alt 7 (No Herb )
Alt 8 (Full eco )
Alt. 9(NPA)
'519
+389
♦325
♦283
-106
-148
-690
♦271
(•599)
(♦469)
(♦404)
(•363)
(+ 80)
(- 27)
(- 68)
(-611)
(♦351)
♦651
♦488
♦407
•355
-133
-185
-866
♦340
(♦751)
(♦588)
(♦507)
(•455)
(♦100)
(- 33)
(- 85)
(-766)
(♦440)
•18
• 15
• 11
• 9
- 4
- 5
-24
• 9
(♦21)
(•16)
(•14)
( + 12)
(♦ 3)
i- D
(- 2)
(-21)
(♦12)
•1.135
• 851
+ 710
• 619
- 232
- 323
-1.509
• 593
(♦1.309)
(♦$120)
(• 884)
(♦ 793)
I' 17-1)
(- 58)
(- 148)
(-1,335)
(♦ 767)
•1.514
♦1.135
+ 946
• 826
- 310
- 430
-2.012
• 791
•1,746)
♦1,367)
+ 1.178)
♦1,058)
• 232)
- 77)
- 198)
-1.780)
♦1.023)
•$133
•S100
•$8 3
♦S 7 2
-$2 7
-S 38
$17 7
♦$6 9
(♦$15 3)
(♦$120)
(+$103)
(♦$ 9 3)
(•$ 20)
(-$ 7)
(-$ 17)
(-$15 6)
(♦$ 90)
•$184
♦S138
+$11. S
•$10.0
-$ 3 8
-$ 52
-$245
♦$ 9.6
(•$21 2)
(♦$166)
(♦$143)
(+$12 9)
(•$ 28)
(-$ 9)
(-$2 4)
(-$21 6)
(•$124)
Employment and
earnings dependent on
the No Action
(Existing Condition)
harvest level 201
(187 5) MMbd tt/year
1.186
(1,106)
1,487
(1,388)
41
(38)
2.593
(2.419)
3,457
(3.225)
$30 3
($28 3)
$42
($392)
Average of all sources
in county and region
1977-1980 (Tables 2-
17 & 2-18)
8.500
(8500)
35.100
(35.100)
NA
(NA)
35.000
(35.000)
246,300 (246.300)
$493 5
($493 5)
$3,073.5
($3,073.5)
Percent of Roseburg
BLM of county and
regional average 1977-
1980
1 4 0%
(13 0%)
4 2%
(4 0%)
NA
(NA)
74%
(6.9%)
1 4%
(13%)
6 1%
(57%)
I 4%
(1.3%)
NA Estimates of <
;ounty totals are not available.
annual receipts from public domain revenues from
the district would vary from $30,100 in Alternative
1 to $8,700 in Alternative 8 under the FY 1981 sales
average of $260 per M bd. ft.
In comparison to a continuation of the harvest
levels which prevailed from 1976 to 1980 (existing
condition), Alternatives 1 through 5 and 9 all
increase employment and personal earnings
dependent on the harvest of timber from public
lands administered by the Roseburg District. In
contrast, Alternatives 6 through 8 yield lower
levels. Employment and income changes related to
fishing, hunting and other recreation are expected
to be insignificant for the short term. In the long
term, slight declines in fishing would occur in
Alternatives 1-3 and slight declines in hunting
would occur in all alternatives except 6 and 8.
Relative to Alternative 4, Alternative 3 emphasizes
current benefits at the expense of increased timber
production beginning 140 years from now. See the
Impacts to Vegetation, Conclusions, discussion.
Clearcutting and the use of herbicides would
continue to be controversial due to concerns of
some residents, particularly adjacent landowners,
about ecosystem damage or health damage as
opposed to the concerns of other residents for
economic benefits in timber production.
Alternatives calling for rates of clearcutting higher
than under the existing plan would be perceived
by some persons as increasing the risk of
downstream damage from flooding and washouts.
Another perception of some residents is that
increased timber harvest levels would decrease the
level of low summer water flows. The impacts on
personal and community concerns of specific
actions such as timber sales and herbicide
application would depend in part on the locations
of the activities as well as on the manner in which
BLM communicates with affected residents.
As shown in the survey cited in Table 2-27, more
residents of southern Oregon favor increased
timber production than favor increased hunting
and fishing or wildlife habitat. Although the net
impact of these concerns is difficult to assess--
depending on the intensity of the concern, the
knowledge of the holder and the specific
alternatives being compared—it is likely that an
alternative that reduced BLM timber sales would
not be favored by a majority of southern Oregon
residents. Concerns for economic welfare and its
relation to dependency on timber harvest have
undoubtedly deepened since the survey as a result
of the current recession.
Conclusions
As noted in Chapter 2, the regional economy
is tightly linked to wood products employment.
The currently depressed levels of employment in
that sector are related to demand conditions in the
86
Table 3-19 Projected Distribution of O&C Payments from SYUs to Counties
by Alternative
(Average annual disbursements in millions of dollars, 1984-1993)
Alt. 1 Alt. 2 Alt. 3
Alt. 4
Alt. 5 Alt. 6 Alt. 7 Alt. 8
Alt. 9
Max.Tbr. Emp.Tbr. Low MHS
OPA
No Action HD No Herb. Full Eco.
NPA
Total O&C Disbursements 1
Douglas County @$ 94/M bd. ft.
3.3 3.0 2.9
2.8
2.3 2.1 2.0 1.0
2.8
@$260/M bd. ft.
9.1 8.4 8.0
7.8
6.3 5.7 55 26
7.8
All Oregon Counties
receiving O&C @$ 94/M bd. ft.
13.1 121 11.6
11.3
9.1 8.3 8.0 3.8
11.2
disbursements @$260/M bd. ft.
36.2 33.5 32.1
31.2
25.2 22.9 22.1 10.5
31.0
Change in O&C Disbursements Compared to Existing Conditions (187.5 MM bd. ft. per year) 2
Douglas Gounty @$ 94/M bd. ft.
- 0.2 - 0.5 - 0.6
- 0.7
- 1.2 - 1.4 - 1.5 - 2.5
- 7
@$260/M bd. ft.
+ 5.6 + 4.9 + 4.5
+ 4.3
+ 2.8 + 2.2 + 2.0 - 0.9
+ 4.3
All Oregon
Counties
receiving O&C @$ 94/M bd. ft
- 1.1 - 2.1 - 2.6
- 2.9
- 5.1 - 5.9 - 6.2 -10.4
- 3.0
disbursements @$260/M bd. ft.
+22.0 +19.3 +17.9
+ 17.0
+ 110 + 8.7 + 7.9 - 3.7
+ 16.8
Change in O&C Disbursements Compared to the No Action Condition (201 MM bd. ft. per year) 3
Douglas County (5)5 94/M bd. ft.
- 0.5 - 0.8 - 0.9
- 1.0
- 1.5 - 1.7 - 1.8 - 2.8
- 1.0
@S260/M bd. ft.
+ 5.3 + 4.6 + 4.2
+ 4.0
+ 25 + 1.9 + 1.7 - 1.2
+ 4.0
All Oregon
Counties
receiving O&C @$ 94/M bd. ft.
- 2.1 - 3.1 - 3.6
- 3.9
- 6.1 - 6.9 - 7.2 -11.4
- 4.0
disbursements @$260/M bd. ft.
+21.0 +18.3 +16.9
+ 16.0
+ 10.0 + 7.7 + 6.9 - 4.7
+ 15.8
' $94/M bd. ft. is the average value of tim
ber sold by the District in FY 1982. $260/M bd. ft. is the average value of timber sold by the
District in FY 1981. All calculations assume that in each alternative a constant 3.6
percent of the annual harvest would be from
CBWRand PD land.
'' The range of projected total O&C disbi
jrsements is contrasted against the existing conditions baseline established in table 2-24,
DEIS. (187.5 MM bd. ft. per year times 96.4% O&C times $157 per M bd. ft.]
I
•' The range of projected total O&C disbursements is contrasted against the no action condition harvest level times the 1976-1980
average receipts per M bd. ft. ($157) times percentage O&C harvest.
Table 3-20 Projected Distribution of Severance Taxes on CBWR Lands by
Alternative
(Average Annual Disbursements in thousands of dollars, 1984-1993) 1 - 2
Alt.1
Max. Tbr.
Alt. 2
Emp. Tbr.
Alt. 3
Low MHS
Alt. 4
OPA
Alt.5
No Action
Alt. 6
HD
Alt. 7
No Herb.
Alt. 8
Full Eco.
Alt. 9
NPA
@$94/M bd. ft.
@$260/M bd. ft.
44.1
122.1
40.8
112.8
39.1
108.2
38.0
105.2
30.7
84.9
28.0
77.3
26.9
74.4
12.8
355
37.7
104.4
Change in Severance Tax Distribution Compared to Existing Condition
(187.5 MM bd. ft. per year)
@$ 94/M bd. ft.
- 3.7
- 7.0
- 8.7
- 9.8
-17.1
-19.8
-20.9
-35.0
-10.1
@$260/M bd. ft.
+ 74.3
+65.0
+60.4
+57.4
+37.1
+29.5
+ 26.6
-12.3
-566
Change in Severance Tax Distribution Compared to No Action Condition
(201 MM bd. ft. per year)
@$94/M bd. ft.
- 7.2
-10.5
-12.2
-133
-20.6
-233
-24.4
-38.5
-13.6
@$260/M bd. ft.
+ 70.8
+61.5
+56.9
+ 53.9
+33.6
+26.0
+ 23.1
-158
+53.1
' At present, the district sells approximately 5.1 MM bd. ft. of timber from CBWR lands each year. The impacts displayed in this table
assume that the District will continue to obtain roughly 2.5 percent of its annual cut from CBWR lands. Property taxes paid would
not vary by alternative.
'' The seven tax districts in Douglas County which share the severance tax distribution are Douglas County, Umpqua Community
College, Douglas Education Service District, and the Oakland, Camas Valley. Winston Dillard and Roseburg School Districts. See
Table 2-21 for the distribution of taxes from CBWR lands in recent years.
87
national economy. Beneath today's concerns are
projections for a dip in wood products production
in the 1980's and 1990's due to the availability of
timber. Alternatives 1 through 4 and 9 increase
timber supply from the district and therefore would
mitigate dips in employment projected to occur
independent of actions by BLM. Alternatives 6
through 8 reduce local timber supply and would
intensify the projected downturn. If timber job
losses were associated with a mill closure, workers
in the core work force would be unemployed.
Older workers might not be able to obtain new
jobs. The personal losses would be great for those
individuals deprived of their functional relationship
to society.
89
Chapter 4 Consultation and
Coordination on the Draft
Environmental Impact
Statement
The Draft Roseburg Timber Management
Environmental Impact Statement (Interior DEIS
82-27) was filed with Environmental Protection
Agency and released to the public on June 22,
1982 and open to comment until August 23, 1982.
A public hearing on the draft was held August 18,
1982 in Roseburg, Oregon. Oral testimony was
presented by five people in the afternoon session
and by 14 people in the evening session.
A total of 95 letters were received in response to
the draft environmental impact statement. These
are listed in the order received in the Response to
Written Comments section. Substantive comments
were identified in 29 letters and they, together with
responses, are printed on the following pages.
Copies of all comment letters and the hearing
transcripts are available for review in the Oregon
State Office, 825 N.E. Multnomah Street, Portland,
Oregon and Roseburg District Office, 777 N.W.
Garden Valley Blvd., Roseburg, Oregon.
All letters and hearing testimony were reviewed
and considered. Comments that presented new
data, questioned facts on the adequacy of the
impact analysis, or raised questions or issues
bearing directly on the draft EIS are responded to
in this final EIS. Some persons both testified orally
and submitted written comments, resulting in
duplication of comments. These comments are
responded to in Response to Written Comments.
90
Several reviewers made various resource
management recommendations. These
recommendations, as well as all public input, will
be considered before the final decision is made.
Consultation and coordination also took place
with many Federal and State agencies and local
governments. Most extensive were coordination
efforts with the following: USFS, Umpqua National
Forest, Oregon Department of Forestry, and
Oregon Department of Fish and Wildlife.
Response to Comments
Common Issues
Five broad issues were raised frequently by
reviewers. These issues and responses to them are
presented below.
Common Issue 1: Wildlife impacts largely dwell on
possible long-term effects and not the period of
the 10-year plan. Adequate old growth would be
available after one decade not to affect
populations of many wildlife species regardless of
alternative.
Response: The text has been revised in the FEIS,
Chapter 3, Impacts on Animals section, to include
additional discussion regarding short-term
impacts on wildlife.
Common Issue 2: In this economic climate how
can you be certain of the indicated level of
funding necessary to implement the intensive
management practices? Please display a variety of
funding levels for each alternative.
Response: The district's choice of a Preferred
Alternative is based on factors other than funding
(see Appendix A). The following table shows
various levels of budget and volume offered for
sale for the Preferred Alternative (Alternative 9).
Common Issue 3: The DEIS does not provide
sufficient detail on the level of intensive
management practices proposed for each
alternative. Please display this information as well
as the proportion of harvest attributable to each
practice.
Response: The following table displays
contributions to the allowable cut associated with
each intensive management practice for
Alternatives 4 and 9.
Contribution
to Annual Harvest
Alt. 4
Alt. 9
(OPA)
(NPA)
Intensive Management Practice
MM bd. ft.
MM bd. ft.
Intensive Base
Harvest and Reforestation
183.0
183.1
Precommercial/
Commercial Thinning
26.0
26.0
Fertilization
12.2
12.2
Tree Improvement
19.1
19.1
Sub Total
240.3
240.4
Constrained Base
Harvest and Reforestation
9.1
6.3
Total
249.4
246.7
Alt. 9 (NPA) at Varying Funding Levels
(in thousands of dollars)
Full Program With
Full
No.
No. PCT
Major Program Area 1
Program
Fert.
or Fert.
Transportation Systems 2
$1,683.0
$1,599.9
$1,422.7
Timber Management
7,120.9
6,419.5
5,414.6
Fire Management 3
525.1
499.1
443.8
Wildlife
128.0
128.0
128.0
Soil, Air, Water
100.0
100.0
100.0
Total
$9,557.0
$8,746.5
$7,509.1
Allowable Cut Level MM bd. ft.
247
235
209
' Program areas directly related to harvesting or reforestation and growth
2 This does not include funding for bridge, road, and aggregate production projects handled through the Federal Highway Administration.
Funds for these projects are held at the State Office. An additional $500,000 is needed for these construction projects.
3 Program areas directly related to reforestation and growth.
91
Common Issue 4: The DEIS does not provide
sufficient detail on forest production opportunities
foregone by various allocations by alternative.
Response: The following table displays timber
volume foregone for each EIS alternative by land
use allocation category.
Timber Volume Foregone in Allocation Areas
Million Board Feet Production/Year, Scribner (MM bd. ft./Yr.)
El S
3
ALTERNATIVE
4 5 6
.5
.5
.5
2.5
4.0
.5
.5
.9
2.5
.5
4.9
.5
.5
.9
2.5
.5
49
.5
.5
.9
2.5
.5
4.9
Land Use Allocation
Category
No Planned Harvest Areas
Botanical
Cultural
Recreation
Bald Eagle
Golden Eagle & Raptor
Old Growth Blocks
Riparian Areas
Sub-Total Volume Foregone
Constrained Harvest Areas
VRM II
Bald Eagle
Northern Spotted Owl
80-Acre Blocks
Old Growth Blocks
Osprey/Heron
Mid-age & Old Growth-
Riparian
Sub-Total Volume Foregone
Minimum Harvest Age
Constraint on
Intensive Base
No Use of Herbicides,
Fertilizers or
Computed Genetic Gain
Total Timber Volume
Foregone
Allowable Cut Level
1 Alternative 5 utilizes the 1970 land base, inventory and allowable cut projections.
? For these alternatives, mid-age and old growth allocations managed under modified area control includes: VRM II, Northern Spotted
Owl, and osprey/heron habitat.
3.7 2
22.0 2
22.0 :
10.4
10.1
10.1
14.1
32.1
32.1
.5
.5
.5
.5
.5
.5
.5
.5
1.8
.9
2.9
.9
2.5
2.3
1.0
.5
1.9
0.5
13.8
22.8
20.5
68.0
12.2
38.1
4.9
96.6
16.9
10.5
21.6
1.6
4.1
C
8.0
14.0
46.0
46.4
1.1
.7
54.0
22.0 2
10.1
60.4
22. 3 :
67.2
32.1
86.8
22.3
7.0
7.0
4.7
80.0
25.6
7.0
4
26
37
44
1
110
117
209
46
289
267
256
249
201'
183
176
84
247
92
Common Issue 5: Several respondents reacted to
data displayed in Table B-6 of the DEIS, which is
shown below. Particular concern was expressed
over the magnitude of the district's average
management costs per acre in the first years of
reforestation.
Baseline Yields, Costs and Revenues
(MCF, Dollars Per Acre)
Douglas Sustained Yield Unit
Full Intensive Management Regime: Plant improved stock, precommercially thin where needed,
commercially thin at ages 35 and 55, fertilize at ages 12, 35, 45, 55, 65 and final harvest at age 75.
Expected
Diameter
Gross
Logging
Hauling
Estimated
BLM
Age
of
Volume
of
Pond Value
Revenue
Cost
Cost
Sales Values
Management
t
Stand
MCF/Acre
Harvest
Per MCF
Per Acre
Per Acre
Per Acre
Per Acre
Costs
557 95
Site prep , plant, protect
1
50 54
Replant, protect
2
50 54
Replant, protect
7
1607
Release
12
1372
Precommercially thin & fertilize
35
361.09
Commercially thin & fertilize
45
71 64
Fertilize
55
361 09
Commerically thin & fertilize
65
71 64
Fertilize
75
28945
Final harvest
'35
1.068
10.34
742 08
792 54
88663
125 16
-21925
55
2.734
12 78
914 86
2501.23
1310.23
320 42
870.57
75
9,129
2042
1455.85
13290 46
1877,12
1069 91
10343,41
35
1.068
10,34
1385 56
1479.78
886 63
125.16
467,97
55
2.734
1278
244052
667239
131023
32042
5041,73
75
9,129
20 42
554880
50655 08
1877.12
1069 91
47708 03
South Umpqua Sustained Yield Unit
Full Intensive Management Regime: Plant improved stock, precommercially thin where needed at age
15, commercially thin at ages 45 and 65, fertilize at ages 15, 45, 55, 65, 75 and final harvest at age 85.
Expected
Diameter
Gross
Logging
Hauling
Estimated
BLM
Age of
Volume
of
Pond Value
Revenue
Cost
Cost
Sales Values
Management
Stand
MCF/Acre
Harvest
Per MCF
Per Acre
Per Acre
Per Acre
Per Acre
Costs
557.95
Site Prep , plant, protect
1
50 54
Replant, protect
2
50 54
Replant, protect
7
16 07
Release
I.'
137.2
Precommercially thin & fertilize
45
361.09
Commercially thin & fertilize
55
71.64
Fertilize
65
361 09
Commercially thin & fertilize
75
71.64
Fertilize
85
28945
Final harvest
'45
1.754
11.58
829 88
1455,62
107509
20556
174 96
65
2,108
1374
98283
2071.82
1035.39
247.05
789 36
85
8.811
20 40
1454,43
1281502
183344
103264
9948 92
45
1,754
11 58
1852.12
3248 62
107509
20556
1967.96
65
2,108
13.74
3078 50
6489 49
1035 39
247 05
5207 03
85
8.811
20 40
6626 05
58382.15
1833 44
1032 64
5551605
' Revenues and costs maintained at 1978-1980 levels
2 Timber values appreciate 1 8 percent per year faster than management costs
93
Response: In the scoping process a member of the
public requested that an analysis of the economic
efficiency of forest management practices be
made. This person also requested that the genetic
yield, costs and revenues used in the analysis be
displayed. Table B-6 of the DEIS summarized
those data for a hypothetical average acre in the
Roseburg District.
Arrayed below are the district's experienced costs
by treatment, and the derived average cost per
acre used to calculate the baseline figures listed in
the table above. Treatment costs per acre were
based on the district's contracting experience from
1978-1980. Each practice is applied only to areas
needing treatment. The average cost per acre
regenerated equals the cost of the treatment times
the proportion of acres receiving treatment.
Roseburg
District Cost for the
Cost per Average Acre
6
Age of
Acre 1
Table B-i
Stand
Treatments
1978-1980
DEIS
Burning
$189.28
161.07
Scarification
63.64
4.86
Paper Mulch
495.72
13.64
Herbicide
63.18
43.30
Initial plant
115.49
115.49
Seed and
Seeding
Cost
100.30
100.30
Artificial
Shading
212.62
59.33
Protection
Against
Big Game
269.73
42.40
Rodents
269.73
13.79
Livestock
74.12
3.77
Sub Total
557.95
1, 2
Herbicide
62.08
6.96
Protection
264.96
12.52
Replant or
Interplant
137.27
21.14
Seed and
Seedling
Cost
100.30
9.92
Sub Total
50.54
Release
63.79
16.07
' Includes district planning, contract preparation and administration,
overhead and contractual costs
94
Response to Written Comments
Each written comment letter from individuals,
organizations or agencies was assigned an index
number in consecutive order as received.
Letter
No. Agency, Organization or Individual
1. Rogue Valley Council of Governments
2. USDI, Bureau of Mines
3. 1000 Friends of Oregon
4. Oregon State Dept. of Forestry
5. Cheryl Kolander
6. L.J. Fullerton
7. Wildlife Management Institute
8. Riddle Laminators (17 signatures)
9. Seek, Inc., Realtors
10. Larry D. Higbee
11. Umpqua Chapter, Southern Oregon
Resources Alliance (SORA)
12. Oregon Wilderness Coalition
13. Dale S. Sawyer
14. Rodney F. Greene
15. Umpqua Valley Audubon Society
16. Umpqua Valley Audubon Society
17. Clifford M. Bryden
18. Gordon Thoreson
19. L.A. Kostur
20. Umpqua Dairy Products Co.
21. Umpqua Savings and Loan
22. Commercial Title Co.
23. Bohemia Inc.
24. Harmony Farm
25. Western World Realty, Inc.
26. Thomas A. Lawler
27. Wayne Peterman
28. Lorraine Michal
29. Champion International Corp.
30 James A. Little
31. Glide Lumber Products Co.
32. USDI, National Park Service
33. Richard Chasm
34. Douglas National Bank
35. Roseburg Area Chamber of Commerce
36. L.L. Burr Logging Co., Inc.
37. Robert Dahne
38. Mary Lou Goodin
39. Les Sanders
40. Becky Nelson
41. Barbara Nelson
42. N. Carlene and W. Rick Wilkinson
43. Umpqua Community College
44. Sun Studs, Inc.
45. Lois J. Gilbert
46. Stuart Richert
47. Weyerhaeuser Company, Western
Oregon Region
48. William L. Streitz, M.D.
Letter
No.
Agency, Organization or Individual
49.
Bob Flynn
50.
Ralph Saperstein
51.
Joel Rosenberg
52.
Lloyd R. Van Doren
53.
Ronald V. Widener
54.
Dale Bonnell
55.
Gene H. Landout
56.
Howard W. Johnstone
57.
Mark and Roberta Kincaid
58.
Roseburg Lumber Co.
59.
Mark A. Lowry
60.
Lynda Oebel
61.
Chuck Kempas
62.
The Neil Company Realtors
63.
John Rard
64.
Mrs. T.L. Suhrstedt
65.
James R. Fourtner
66.
Mrs. R.J. Parlik
67.
Carolee Fourtner
68.
Douglas Timber Operators
69.
Association of O&C Counties
70.
Ken Shrum
71.
Western Forest Industries Association
72.
Wade Mosby
73.
Richard Mitchell
74.
USDI, Fish and Wildlife Service
75.
City of Sutherlin
76.
William E. Markham, State Representative,
District 46
77.
Richard Croucher
78.
Harold F. Anderes
79.
Floyd G. Sackett
80.
Associated Oregon Loggers, Inc.
81.
Jozef Reynaerts
82.
Corey John Bidwell
83.
North West Timber Association
84.
William C. West
85.
Oregon Dept. of Fish and Wildlife
86.
U.S. Environmental Protection Agency
87.
Ellis W. Antrim
88.
Marilyn J. Smith
89.
Duane L. Smith
90.
USDA, Forest Service, Pacific
Northwest Region
91.
Industrial Forestry Association
92.
Cecil and Phyllis Hubbs
93.
Cameron LaFollette
94.
USDC, National Oceanic and
Atmospheric Administration
95.
Oregon Executive Dept., Intergovernmental
Relations Division
2-1
United States Department of the Interior
BUREAU OF MINES
WISI IRN Hill) OPERA I IONS ( INI t.K
I \si IGO )RD w h Nil
sink \si . \s \sllls, I ms , i
July 22, 1982
Memorandum
To: James E. Hart, District Manager, Bureau of Land Management,
Roseburg, Oregon
From: Chief, Section of Minerals Involvement
Subject: Draft Environmental Impact Statement (DEIS) for the
Roseburg Timber Management Plan
We found the statement well written except for lack of comments on mineral
resources. The proposed action is not expected to adversely affect mining or
mineral resource utilization in the area. However, the disclaimer on page 63,
that the proposed action will not significantly affect mineral resources,
should be preceded by at least a brief discussion that describes the existing
mineral related activities.
The discussion of socieconomic conditions fails to mention the strategic
importance of the only operating nickel mine in the United States. This mine,
the Hanna Nickel Mine located near Riddle, in Douglas County should also be
described briefly because of its' economic importance to the local community.
Thank you for the opportunity to review the draft statement.
95
Response to comments in Letter 2.
The purpose of EIS scoping is to focus only on those issues that
relate to significant effects of the EIS alternatives Analysis,
including the scoping process, indicated that timber management would
not significantly impact mining or future mineral resource
utilization. Therefore, as stated on page 63 of the DEIS, these
topics are not discussed.
D. P. Banister
1000 FRIENDS OF OREGON
400 DEKUM BUILDING, 519 S W THIRD AVENUE, PORTLAND. OREGON 97204 (503) 223-4396
Response to comments in Letter 3.
3-1
July 19, 1982
Bureau of Land Management
Roseburg District Office
777 N.W. Garden Valley Blvd.
Roseburg, OR 974 70
Re : Roseburg Timber Management DEIS
To Whom It May Concern,
I am writing to express concern over the omission of
a discussion of certain recent studies by Dr. Robert R. Curry
in the subsection entitled "Impacts on Soils" in Chapter 3
"Environmental Consequences " at pages 64-66 .
Dr. Curry, on the faculty of the University of Cal-
ifronia, Santa Cruz, testified before Congress in 1971 that
"[p] resent evidence suggests forest cutting, by any but the
most conservative and careful methods appears to completely
defeat the nutrient cycling and soil nutrient storage capacity,
as well as increase erosion . Western forests may have less
than 200 years of productive fertility remaining before per-
manent. . .eradication of productivity for saw timber production,
since then Dr. Curry has refined and expanded his hypotheses
and is chairing a National Academy of Science Study on its
relevance to agriculture .
It is distrubing that such a fundamental issue as
longterm soil productivity should be treated in such a
summary fashion that Dr. Curry's work is not cited once. Soil
productivity is one of the fixed limitations which should con-
trol the decisions concerning use of and investments in, our
national forests .
3-1 The literature includes many authors whose work has not been cited in
the DEIS. Although the literature is not conclusive, recent work has
shown soil productivity to be affected as indicated on page 66 of the
DEIS
This issue was also addressed in the promulgation of guidelines by
the 92nd Congress. Titled "Clearcutting on Federal Timberlands,"
Report by Subcommittee on Public Lands (commonly referred to as the
Church Report), this document has been adopted by BLM as indicated on
page 19 of the DEIS.
RL/cms
Forestry Department
OFFICE OF STATE FORESTER
260O STATE STREET SALEM. OREGON 97310 PHONE 3782560
July 28. 1982
Mr. James E. Hart, District Manaoer
Roseburg District
Bureau of Land Management
777 N" Garden Valley °!vi.
Roseburg, Oregon 97470
Dear Mr. Hart:
The Oregon State Forestry Department has reviewed the Roseburg Timber
Management Draft Environmental Impact Statement . We are pleased to note
the consistency of the proposed action with the basic objectives of the
Forestry Program for Oregon, especially with regard to the production of
timber.
While we support the direction of the proposed action I am particularly
concerned with the need to conserve the existing commercial forest land
base as an essential element to offset projected timber supply shortages
in this Timbershed. We would like to offer comments in four general
areas including; selection of an alternative, consistency with the
Forestry Program for Oregon, intensive management and the scattered owner-
ship pattern.
I hope these comments will be useful and I trust they will be given adeguate
weight and consideration in the final environmental impact statement.
H. Mike Miller
State Forester
HMM:jp
cc: Board of Forestry
Executive Staff
Congressional Delegation
Pat Amedeo
Tom Lane
William Leavell, BLM State Director
State Clearinohouse (PNRS #0R 820628-068-4)
4-1
Oregon State Forestry Department Review of
Roseburg District Timber Management
Draft Environmental Impact Statement
During our coordination effort, the Forestry Department has raised a number
of issues at various Input stages In the planning process. Some of these
concerns have been resolved, however we dre interested in further discussion
of the following issues In the EIS.
Selection of an Alternative :
Generally we support the direction of the preferred alternative since
it provides a harvest level and proposed management program comparable
to the "Objective" level identified in the 1980 Timber Supply Assessment
for the Roseburg Timbershed. In brief, the Assessment points out that
while BLM is nresenMy harveitino timber at a reasonably attainable level
in western Oregon, overall harvest levels in most tlmbersheds are ex-
pected to decline. BLM could help alleviate this potential shortfall by
increasing its present harvest by an averaae of 7% in western Oregon.
Consistency with FPFO :
It is the Board of Forestry's policy to promote a statewide Forestry
Program for Oregon which meets certain objectives: maintain the existing
commercial forest land base, maintain or increase the annual allowable
harvest, utilize a full range of intensive management practices, and main-
tain community stability.
Forestry has encouraged the BLM to be consistent where possible, with these
State objectives.
A table showing BLM harvest projections from the 1980 Assessment were
provided your office in a memorandum dated July 19, 1982. We would like
to incorporate these harvest levels into the consistency table as a bench-
mark for comparison of community stability.
The reasonably attainable harvests for the Roseburg District would be:
1980 1990 2000 2010 2020
MMCF 40.3 39.5 39.2 38.8 38.7
As you note, the harvests projected are not constrained by an artificial
limitation such as non-declining even flow, but are in accord with the prin-
ciple of sustained yield.
Additionally, we feel some limited opportunities exist to increase this
harvest level in some timbersheds from a "surplus inventory" or as a
"cooperative harvest" target. This increased harvest is intended to make
up for the "fall down" expected in some timbersheds to ease community
transition to a sustained harvest from all owners.
Intensive Management :
In order to rank alternatives
Objective to maximize growth
4 — 2 |P ract ' ces - tne EIS should dis
I of practices that are accompl
Information in the DEIS does
sive management practices in
of Proposed Action and Altern
4-3
4-4
types and levels of treatment
the process of computer model
because most of the land base
in needed treatments currentl
these projections make meanin
accordino to thei
through increased
play the differenc
ished and that pro
not provide a basi
a comparative mann
atives by Treatmen
r consistency with the FPFO
intensive management
e between the current level
posed for each alternative,
s by which to measure inten-
Table 1-2 titled Comparison
First Decade displays the
as a comparison
ing acres tend to
over time is cons
y and combinations
gful comparisons d
with the proposed action. In
be treated by percentages and
idered for treatment, backlog
of treatments occuring during
ifficult.
In the FPFO consistency table our benchmark is to "implement a full range
of intensive timber management practices for optimization of timber pro-
duction". Using the information in your table this could be a comparative
target number such as a percent of the CFL land base receiving basic inten-
sive management treatments during the first decade.
To better provide a benchmark consistency target, OOF suggests that you
display acres for each of the basic intensive forestry practices implemented
as a percent of the CFL base projected for each decade.
We estimate that 35% of the CFL base currently receives some intensive
management treatment. (Plant, Rehb. Release, PCT, CT and fertilization).
The Preferred Alternative would result in about 65% treated. Alt. 1, 2
and 3 are greater than 65% and Alt. 6, 7, and 8 are less than Alternative 5
and would be inconsistant with FPFO in our opinion.
Scattered Ownership Pattern :
One issue not addressed in the DEIS is the checkerboard pattern of ownership
characteristic of & C lands. The operational problems due to this
pattern affect the management programs for both commercial timber production
and amenity values. It is uncertain how the objectives of programs for
visual resource and wildlife habitat can be implemented with uniformity and
measured objectively. This problem needs to je disc-^s?-i in cone details
in the Environmental Impact Statement.
Response to comments in Letter 4
4-1 FPFO forest harvest levels for the 1980 decade have been incorporated
by text revision (see FEIS Chapter 1 State and Local Governments
under Interrelationships section).
In addition, FPFO harvest levels for decades 1980 - 2070 are shown
below Volumes in MM bd. ft. were converted frcm 32-foot to 16-foot
log rule for direct comparison throughout the EIS.
BLM Harvest Projections - 1980 TSA
(MMCF & MMBF/Yr jl
Decade
BLM Unit 1980 1990 2000 2010 2020 2030 2040 2050 2060 2070
Roseburg
MMCF 40.3 39 5 39.2 38-8 38.7 38. 2 37.7 37.2 37.0 36 7
MMBF 245.4 235.4 247.1 237.7 208.3 160.8 141.6 161.3 168.7 167.2
i Harvest in each decade sustainable for seven additional decades in cubic
feet (incremental even-flow). Harvest in board feet is based on 16-foot logs,
Scribner Log Rule. Converted by D. Preston (OSO) 8/4/82 frcm OSDF original
submission
4-2 The following tables sh Tactices
i .
i Ac. Planned Ac. Planned
; i ice (1 972-1981)* A lternative 4** Alternative 9*
31,866 103,010
102,197
68,027
97
The acres toe each intensive management practice planned for the
first decade are shown in DEIS, Table 1-2. On the commercial forest
land base 92.5 percent of the intensive management acres harvested in
the first decade will receive spacing control and fertilization,
planting with genetically improved stock will also occur on
approximately 30 percent of the acres harvested in the first decade.
This would increase to approximately 92.5 percent by the fourth
decade.
2,289
31,076
40,284
9,365
Ac. A i Ac. Planned
(1972-1981)* Alternative 4*
Ac. Planned
Alternative 9*
14 , J45 40,755 40,449
Lnning 1 , 119 3,479 1,383
56,029 55,646
15,200 15,200
146
24,964 3,347 3,328
■ i wth Man3jejnent Camiittee Report
:• L-2
Other harvested acres would not be subject to intensive timber
management practices that are yield enhancing.
By the fifth decade all intensive management practices would be
scheduled at maximum levels. The percentage of commercial forest land
scheduled for each intensive management practice is shown below:
Percent Commercial Forest Land Base*
Scheduled for Intensive Management
(Fifth Decade and Beyond)
EIS Alternative
2 3 4 5 6 7
85 79 79 23 53 37
8 9
78
Intensive Mgt.
Practice
Spacing Control
( Pre . Carml . &
Comml . Thinning)
Fertilization
Tree Improvement
•Percent scheduled by practice (Commercial Forest Land Base 391,070
M
85
79
79
53
78
9]
85
79
79
73
53
68
78
•) on page 82 of the DFIS. BUI recognizes the "ability to
- quality is often 1 united by
■■
ler the various alternatives also
i ownership.
It is not the Lnten! ontrol or influence private land
management decision-, ■ r red or any of the other
alternati k+i <.>>ntf)i ■ ,r influence.
5-1
D! iJT E.I.S.
1.
rile
5-2 1
- ■ ■ . ons, but rbther,
-T.snt alternatives must be discussed. In .specific, the alternative
--vest: var >f sevectlve - shelter-
c leer cuttin . of land,
■ .re -rees.
" la -• lysis. Specif] cally:
full-sus ..-.tes.
2.
- er.t error in that :r.e NoM
he acreage re.
: -s to oe reJuced I r« :ed siie, ar.r
size p.- !
rt of tr.e i. . .
5 — 3 | Tnere ., assos sed ne
-
Lvity, recreation, etc., must .lave cleai
■ ■ ■ is pursuant
11 r - J ...suroa ore , iC t 5 are too sevore
to alio* justil ferred Alternative, E iven all applicable conservation
the case no i-res are u bo delineated and odooted, a j-usti:.
Ls must be nude. .. CFS. a worst case scenario sust be
developed and ox i isbj : or public scrutiny.
£^yV^^^
Cneryl Kolander
98
Response to comments in Letter S.
5-1 The public scoping process that preceded development of the DEIS
identified the issues addressed in the EIS alternatives as the most
important and relevant for analysis. The EIS does address several
different timber management options, including: no herbicides, no
fertilizer and smaller minimum harvest size. Specific management
practices, including various harvest methods, are described in the
BLM Timber Management Final EIS 1975, which is incorporated by
reference. Alternative harvest methods are considered on a site by
site basis, utilizing the appropriate method to mitigate a potential
impact.
In the EIS, Chapter 1 references the BI* Tinb i it Pinal EIS
1975, which includes a detailed listing of mitigating measures.
Chapter 1 also describes project design t ■ .i , ■ -•
mitigating measures feasible to implement without changing an
alternative or impacting the allowable cut associated with a
particular alternative. Additional means to mitigate adverse
environmental impacts are discussed in Chapter 3.
The North Myrtle proposed RNA acreage is correct as shown in the DEIS
(Table 2-14). The Proposed RNA was reduced to approximately 240 acres
in the Original Proposed Action (Alt. 4). This protects an area
sufficient to meet RNA cell needs and sensitive plant habitat, while
leaving the remainder open to other management activities. There are
no minimums established for RNA size; some RNAs are 80 acres or less.
Note: the entire 480-acre parcel is part of a serai stage block in
the new Preferred Alternative (Alt. 9).
DANItl A POOIE
i K |AHN
L- L. WILLIAMS! in
Wildlife Management Institute
70S Wire Building. lOOOVefmonl Ave . N W . Wash. ngton, O C 2000$ • 202
August 12, 1982
Mr. James E. Hart
District Manager
Roseburg District Office
Bureau of Land Management
777 NW Garden Valley Boulevard
Roseburg, Oregon 97470
Dear Mr. Hart :
The Wildlife Management Institute submits its comments on ROSEBURG
TIMBER MANAGEMENT ENVIRONMENTAL IMPACT STATEMENT, Oregon. We usually would say
we are pleased to submit comments, but this time it is a sad occasion.
Your plan is good, probably about the best that could be expected
from the lands in the Roseburg District. It is not quite as good for wildlife
as the Coos-Curry plan. However, both have now gone down the tube— negating the
many years work to bring 06.C lands under some kind of multiple use.
We are referring to the July 15 memo from the Director. The third
paragraph throws out Sikes Act and other agreements with the state and other
agencies on spotted owls as "interim." It says in part "Habitat through land
use allocation in these instances on OSC lands will be provided only to the
extent it
7-1
es from noncommercial timber lands."
This is done at a time when, in the real world, some purchased timber
has stood uncut for over 3 years, sales are down and some timber offerings are
not being sold.
Several years ago a humorous sheet was circulated in Oregon giving
a recipe for Roasted Spotted Owl. That may no longer be a joke since July 15.
We see no reason to make our usual detailed analysis of the plan, as
it will be completely changed by the time the final EIS is prepared.
We do wish to call your attention to one important fact, however.
The 423,896 BLM-adminlstered acres contain tracts of Public Domain. This land
is subject to FLPMA. We insist it be managed for multiple uses--and in this
case we define those uses as old growth since somewhere in the OSC mosaic there
should be a tree older than rotation age.
Mr. James E. Hart
August 12, 1982
Perhaps the great need is to repeal the O&C Act, removing the boon-
doggle Oregon counties receive of 75 percent of the long time average $300,000,000
a year from timber sales. This diversion of federal funds still occurs at a time
when our government proposes selling public lands to retire the national debt.
The government does not seem worried about subsidies to Western Oregon counties
or to the livestock graziers of the West.
We view this action as short sighted and a detriment to long-term
management of OSC lands. This reversal to single use management will draw
attention to the basic inequities of the OiC Act and hopefully will result in
its amendment or repeal.
These remarks have been coordinated with William B. Morse, the Institute'
Western Representative.
Sincerely, . — ..
Daniel A. Poole
President
DfOIC<\TEDTOWIMUff
11
99
Response to oanments in Letter 7.
7-1 The Bureau agrees that management of Public Domain (PD) lands is
governed by FLPMA. The Preferred Alternative and most other
alternatives would provide for management of the Public Domain (PD)
lands under multiple use concepts. Due to the small amount of these
lands, i klm analysis showed they cannot by themselves satisfy old
■ objectives for wildlife habitat. The PD lands in
m Oregon are combined with O&C lands for allowable cut
calculation purposes.
August 12, 1982
Mr. James Hart
District Manager
Roseburg District BLM
777 N.W. Garden Valley Blvd.
Roseburg OR 97470
Dear Jim:
The Umpqua Chapter of the Southern Oregon Resource-
to continue its participation in the planning and management &■ I
of the District by submitting our comments on draft EIS
Timber Management Plan.
The goal of our organization is to seek out a balance in resource issues
that provides economic stability for Douglas County, while pro-.
the protection of the environment so key to ma
life we all enjoy. Our membership and our Board of Directors represents
a cross-section of the community from those with strong resource utilization
interests, to those with strong concern for re - environmental
concerns. Contrary to our friends in either the La
groups or the timber industry, we are not single-use or objective oriented.
Furthermore, unlike some local advocate groups, we are aware of the
differences in purpose between BLM and Forest Service management. Indeed,
we believe our organization represents the "community" that the 06C act
referred to when it discussed providing for economic stability, watershed
management, and recreational opportunity.
In reviewing the activities leading up to the draft EIS
board meeting, one factor became quite clear. You and youi
done an outstanding job of listening to the public concerns and
demonstrated a sincere concern for the needs and desires of the majority
of the local population. The dedication and professionalism demonstrated
by you and your staff is most appreciated by our organization.
In reviewing the EIS and recent planning criteria established by the
Bureau, it would appear that our input is needed in two areas:
I. Contrary to other planning efforts, the proposed action can be
changed in the final EIS to reflect Bureau laws and policy leading to the
actual decision. Input should therefore deal with what our organization
believes the proposed action should be in the final EIS.
11-1
11-2
II. The adequacy of the EIS in terms of properly displaying the
environmental and human effects of various alternatives.
During the Boards review of the EIS, it became clear that we, as lay
members of the public, cannot evaluate such technical items as harvest
nptions, road desiqn, environmental mitigation or fish and wildlife
niques. Rather, we must examine such documents from the
vantage point of outputs and how well they meet our criteria for
rtunity, water quality, wildlife populations, complj
with : )'•--, and economic stability in terms of jobs and public
We had ■ the timber industry would be pushing for a full,
inagement option such as described by Alternative
what surprised when the industry asked that SORA
considei joining wi istry in supporting Alternative 2. We
ort because the EIS does
he probata Lity of
alternative. Uscussion and review, the
i SORA was unanomously adopted:
i:R OF SORA URGES THAT THE BLM ADOPT ALTERNATIVE 2
AS THE PROPOSED ACTION IN THE I MENTATION
AS TH DED THE FINAL EIS DEMONSTRATES THAT SORA'S
OBJECTIVES IN THE AREA. TY, RECREATIONAL
ROWTH AND ECON " CNDEED MET BY
"
11 — 3 I T he public should be given the opportunity to comment on specific areas.
We are concerned that some areas, such as Slide Over, may be more political
in nature than based on demonstrated need, or the area's attributes, when
compared to other potential areas in the state.
RIPARIAN AREAS AND WATER OJJALITY -It would appear that with the allocation
of over 18,000 acres of streamside units, that water and fisheries' values
I are well provided for in Alternative 2. In addition, the EIS should analyze
how these areas can best be managed to provide for old growth and other
wildlife needs.
WILDLIFE -We recognize that as the composition of the forest changes from
predominately old growth to a managed forest, there will be changes in the
wildlife populations. However, there will still be an abundant population
of wildlife for the public to enjoy. This concept has not been adequately
discussed or described in the EIS. Considering the O&C
lands, we do not think it necessary that every species now
land must always be found on BLM lands so loi Sone-
where in the region. With the Riparian zone . i LI not
be managed intensivly for timber, this is not a serious concern.
11-5|
Ilt was pointed out in an earlier planning document
decades before any wildlife population will be sigr
think this concept should be carried forward into t
.11 be several
icantly impacted. We
final EIS.
Following are in areas of concern to SORA along
In the analysis in the final EIS.
ith
NORTH UMPQUA RIVER -Qur organization is particularly concerned that your
management of the ri Lc beauty of the area, as
reased recreational pressure on the
area. Because it i: ltive area, it deserves specific discussion
for increased day and overnight use
Increased river crossings for foot traffic, and increased
'he once proposed Bob Butte road. We would
' mprovement oi
RECREAT T naximum recreational
opporti ment. This should include
:i iged forest,
tyout, as well as
■
I \REAS OF CRITICAL ENVIRONMENTAL CONCERN AND RESEARCH-NATURAL AREAS - I t
appears that the ACEC's desicions will be made as part of this planning
, yet the EIS fails to give specific descriptions of the areas that
ild be included, why they are included, or how they would be managed.
11-7
11-8
11-9|
OLD GROWTH AND THE SPOTTED OWL -SORA appreciates the values of old growth
and the apparent uniqueness of the spotted owl. It has also become abundantly
clear in recent months that a great deal of study and research is needed on
the subject, while the EIS indicates the spotted owl will be gone from the
district in a hundred years, the arguments are not at all convincing. We
think that opportunities to manage for the owl without the large habitat
allocation must be examined. Clearly on this district time is not a
critical issue since it will be so long before the major portion of the
old growth is scheduled for harvest.
Your EIS should show the public how many of the owls you can protect for
the first ten years as well as for future decades under each alternative
by carefully scheduling your timber sales. It would appear that we have
several decades in which to determine a proper old growth policy on the
district. In the meantime, the Forest Service will develop its local
plans and the researchers can provide the answers to the many questions.
The EIS should deal with total old growth on the district, not just the
commercial forest lands.
TIMBER SUPPLY AND LOCAL ECONOMIC STABILITY -It is clear at this point that
some significant increases in the even flow sustained yield are possible
from the Roseburg BLM. For this we are thankful, as our industry will need
the timber and our community will need the jobs once the current national
economic climate improves. It is our understanding from the EIS that
actual harvest levels will fluctuate depending upon the funding levels
approved by Congress and the price of timber. It also appears that in order
100
to reach the level of harvest 'ou will need big increases
in funding. We find this very unlikely in the next few years. While we
support youi ry, we are concerned that the
I prop' ii Therefore, we would ask that the
i IS display the harvest level for each Levels
of funding (current, 10* higher or lower, 15* higher or lower, etc.).
11-11
As you know, a timber shortage is predicted for this region in the next
thirty years or so. While you discuss the Forestry Plan for Oregon,
feel a more detailed discussion of BLM opportunities to help protect
shortage should be discussed in your final EIS.
CONCLUSION- Based on the information available, SORA is pleased to support
Alternative 2. It will provide for affordable increases in harvest which
will provide a favorable climate for increased employment and economic
recovery while protecting the environment and preserving the quality of
m Douglas County. Options for future old growth allocations will
remain in place until future plans are developed and better knowledge
ll; available upon which to make rational decisions. We urge that you use
Alternative 2 as the proposed action in the final EIS so that we may more
fully analyze its effects in the decision process.
On behalf of the Board of Directors,
Georgia H. Stiles
President
cc Bill Leavell, State Director
Bob Bur ford. Director BLM
SORA Board of Directors
Response to comments in L/?tt<-r 11.
11-1 The North Umpqua River is discussed on pages 48, S3, and 84 ol
DEIS. Specific development opportunities will hr- addrr-:,
subsequent detailed management plans and environmental assessments.
11-2 Recreation facilities and opportunities are described on pages 47-50,
80-85 and 126 of the DEIS. Additional details are available at the
Roseburg District Office.
11-3 USDI, BLM 1980a {see References Cited) contains general policy and
guidelines for ACECs. Further information, including the proposed
Management Framework Plan (MFP), an ACEC identification summary and
ACEC plan element, is available in the Roseburg District Office. The
identification summary documents the criteria evaluation, staff
analysis and public participation for nominated and proposed ACECs.
The ACEC plan element provides a specific description, management
objectives and special management requirements for all proposed
ACECs. Details were published in Roseburg District Planning
Newsletters 9, 10, 11 and in Brochures on Draft and Preferred Land
Use Alternatives. The public was given opportunity to nominate areas
and comment on potential areas through the response to land use
alternatives from the above listed brochures. Following designation,
activity plans are prepared to translate management requirements into
on-the-ground implementation actions.
11-4 All EIS alternatives, except Alternative 1, provide an allocation for
riparian habitat. Although this habitat meets many wildlife needs,
Lang (1980) states that narrow riparian strips containing old growth
trees do not constitute old growth ecosystems because of the lack of
an old growth microclimate. As a result, opportunities to provide the
needs of old growth dependent wildlife species through riparian
habitats are quite limited.
11-9 The DEIS analysis, including Table 3-9 and Appendices E and F,
addresses all old growth within and outside the commercial forest
land base. Withdrawn areas and non-intensive commercial forest land
have been used to satisfy a variety of resource uses, including eagle
habitat, riparian areas, owl habitat, scenic values, etc.
11-10 See response to common issue 2.
11-5 Refer to DEIS, Chapter 3, Impacts on Animals section, pages 72-77.
Also, see response to common issue 1.
11-11 See response to comment 4-1.
11-6 See response to common issue 1.
11-7 The EIS analysis focused on short- and long-term impacts to the
spotted owl based upon current information. Refer to Chapter 3,
Impacts on Animals, Threatened and Endangered Animals and Conclusions
' sections. Also, see response to comment 83-6.
For the first ten years, under original Task Force guidelines, at
least 25 pairs of owls would be expected to remain under the
Preferred Alternative (Alt. 9) as a result of land use allocations
and harvest scheduling. To assess the effect of timber harvest
actions on spotted owl populations at the end of each decade for each
alternative, it would be necessary to have detailed long-term timber
sale plans. Since this has not been done, the issue cannot be
adequately assessed. Refer to Chapter 1, Table 1-5 and Chapter 3,
Impacts on Animals, Conclusions section.
12
regon Wilderness Coalition
Main Office 271 Wesl 12th Avenue Eugene Oregon 97401 [503 J44-0675
Mi tro i »ffice IX-kum Building, 519 SW ,»rd Avenue, Suite 706, Portland
Oregon 97204 (5031 224-0201
Eastern Oregon Field Office Box 9 Prairii Cit) Oregon 97869 S03 820-3714
101
Response to comments in Letter 12 .
12-1 Under Council on Environmental Quality regulations (40 CFR
1502.14(a)), an EIS must consider a range of reasonable alternatives.
Many reasonable alternatives may be inconsistent with current agency
policy. The possibility always exists that the EIS analysis can lead
to revision or policy.
12-1
We are not so poor we musx destroy oui wilderness, nor so rich we can afford to — newton urury
15
15-1
15-2
Umpqua Valley Audubon Society
P.O. Box 381, Roseburg, OR 97470
August 18, 1982
lr. James Hart, District Manager
Bureau of Land Management
777 N.W, harden Valley Blvd.
Roseburg, Oregon 97470
Dear Mi
Enclosed are our omaniza
Manaaement Environmental
tion s comment
Impact Stateme
nt the comment
ard of directo
nto the draft
was done deta
d result from
o thank some <
nswering quest
Dick Norland .
to meet with
s on the R oseburg Timber
nt issued in June of 19 82 .
iade in the 15-page
We were impressed
statement and felt that
iling many of the environ-
the various alternatives.
f your staff for the time
ions that I had about the
nd Dave Palmer all took
me and I certainly aporeci-
This letter will supoleme
document signed by our bo
with the work that went i
a relatively thorough job
mental impacts which woul
I would especially like
that they spent with me
statement. Bob Albei
from their schedules
ated i t .
Soc io-economic Impacts
The analysis of the economic impacts of the various alternatives is
This part of the impact statement is critical because
ill o^ the dearadinq of the environment that occurs in alternatives
1 throuqh 5 is beina done basically in the name of economics and
community stability. An adequate decision cannot be made unless the
economic analysis is adequate.
1) The statement determines the existing situation to be 187.5
MM bd. Ft. This average is obtained by considering the years 1976
through 1980. The analysis should include the last 10 years rather
than t Lve. In addition it should include the figures for
■ear 1981.
2) The averaqe 12-month harvest should be determined using a
number of different years. If the existing situation were based on
the averaqe harvest for the last three years, i.e. 1979, 1980 and
1981, isults would occur. For example, the
h harvest for 1979, 1980 and 1981 is 159 MM bd. Ft.
this figure as the existing situation, all of the alternatives
15-2
15-3
15-4
15-5
15-6
15-7
Mr. James Hart
August 18, 1982
Page 2
except for alternative 8 would result in an increase in timber
harvesting and alternative 6 would increas e the number of jobs
in the local economy by approximately 400.
3) On cage 87 it is stated that the economic projections
assume that under each alternative the timber is promptly harvested
and processed. The statement should include information on the
current situation. For example, if there is a backlog of timber
that has been sold but not harvested, that information should be
available to the public and the decision maker.
4) The statement should analyze whether the timber market
can support the increased harvesting that is projected by some of
the alternatives. It should analyze the impact that a rapid
conversion of public old growth timber will have on the timber
market. It should attempt to analyze whether a reserve of old
growth timber will have a stabilizing influence on timber prices
and whether a rapid conversion of old growth timber would result
in a substantial increase in the value of privately owned timber.
5} Because one of the main objectives of the O & C lands is
to stabilize local economies, the statement should analyze the
apparent trend towards diversification that is occur ing in Douglas
County. It apoears to be the goal of most Dolicy makers in
Douglas County to diversify the economy so that the swings in the
housing market caused by national recessions will not result in
such dramatic increases in unemployment in Douglas County . I f
some of the alternatives would result in the forest industry in-
creasing its Drecentage of the market place in Douglas County, a
federal bureau could actually be working against local economical
stability.
Water Quality
1) There aopears to be no statement of the actual State and
Federal quality standards which must be met in the sustained yield
unit. This information should be included in the statement.
2) On page 68 it is concluded that substantial increases in
nutrient concentrations following forest fertilizations are not
expected. No sources are given for that conclusion. It certainly
seems that with the amount of research that has been done in
agricultural fertilization, there must be some research available
to indicate whether stream concentrations will increase or stay
the same following fertilization.
Soils
15-8
1) We don't understand why the withdrawals for fragile sites
is so much smaller than the inventoried fragile soils. Table C-2
15-8
15-9
15-10
102
Mr. James Hart
August 18, 1982
| on page 125 would withdraw approxi-
mately 2600 acres for fragile sites. Table 2-14 on page 34 seems
Mcate that there are approximately 9,000 acres of fr
soils.
2) The analysis of the impact of the loss of soil due to
intensive timber management is inadequate. The statement should
irnount of top soil that is being lost from the
forest under each alternative, the amount of top soil that would
be added to the forest under each alternative and it should project
whether those top soil losses can go on indefinitely without affect-
ing the long-term productivity of the sustained yield unit.
Vegetation
1) The statement should indicate the impact that the various
alternatives will have on the present species composition of the
sustained yield unit. I nresume that in many places in the forest
mixed stands will be reDlaced by single species and the states-
I should analyze whether this will vary under different alternatives.
2) If the change in species composition results in conversion
of a mixed forest to a monoculture, the statement should analyze
the environmental impacts of that change.
M iscellaneous
1) Some of the Roseburg district lands are public domain lands
which apparently should be managed under The Federal Land Policy
and Management Act of 1976. These lands should be clearly identified
in the statement and the alternatives should assess the impact that
different legal restraints will have on that land.
12) It appears that some of the alternatives may violate State
and Federal water quality standards. If they do, we believe it is
inappropriate for these alternatives to be considered because they
are not alternatives that could be implemented.
13) The statement should indicate the amount of merchantable
timber that is being added to the sustained yield unit annually at
the present time.
4) The statement should indicate what portion of the projected
harvest under the preferred alternative is due to projections for
15-14 genetically improved trees, what portion is due to precommercial
thinning and commercial thinning, and what portion is due to
fertilization.
15-11
15-15
Mr. James Hart
August 18, 1982
Page 4
I to assess the environmental impacts of their activities on '
and wet lands. ,t able to
concerning the identification of those lands or any asses-
I of the impact of the alternatives on those lands.
At this time we do not expect to be submitting any oral stu'
at the public meeting.
Sincerely,
James A. Arneson
Conservation Committee Chairman
15-151
5) Executive Order 11990 and 11880 directs Federal agencies
Response to ccmnients in Letter 15.
15-1 The average 12-month sales frcm the Roseburg District frcm 1972
15-2 through 1981 was 200.2 MM bd. ft. The average 12-month harvest from
the Roseburg District frcm 1972 through 1981 was 194.9 MM bd. ft.
Fluctuations of over 25 percent above or below the allowable cut are
not uncanmon in tracing the annual harvest through the past decade.
15-3 Timber sold but unharvested in the Roseburg District, as of March 31,
1983, was 616.9 MM bd. ft.
total employment provided by the wood products sector by less than 1
percent For example Table 2-17 reports lumber and wood products
employment in Douglas County (1977-1980 avg.) of 8.500 and total
employment of 35,000 Under the no action baseline (Table 3-18),
Alternative 1 could add 537 jobs in the timber industry with total
employment increasing by 1,135. During 1977 through 1980 timber
industry jobs represented 24.3 percent of total employment in Douglas
County. Under Alternative 1 timber industry jobs would represent
25.0 percent of total employment in the county.
15-4 A number of studies which include estimates of the price-quantity
relationship for lumber and wood products at the national level or
the derived price-quantity relationship for stumpage from public
ownerships in the Pacific Northwest are available (Haynes 1977; Adams
et al. 1977; Adams 1977; Haynes and Adams 1979; Youngday and Fight
1979; Adams and Haynes 1980; and Haynes et al . 1981). All of these
studies suggest that changes in supply of timber of the magnitude of
the alternatives in the DEIS will have no effect on the market
clearing prices of stumpage or manufactured wood products.
15-5 Pages 54-55 and Tables 2-17 and 2-18 of the DEIS discuss and display
recent trends in economic diversification within Douglas County.
Because timber industry jobs support jobs in other sectors (service,
retail trade, non-wood manufacturing, etc.), an increase in the
number of timber dependent jobs would increase the percentage of
15-6 The State of Oregon has determined that the requirements of the
Forest Practices Act meet the objectives of State and Federal water
quality standards. (Refer to ORS 340; copies are available at Oregon
Dept. of Environmental Quality and BLM offices.)
15-7 The text has been revised in the FEIS, Chapter 3, Impacts on Water
Resources, Water Quality section.
15-8 The withdrawals for fragile sites are part of the TPCC inventory and
do not coincide with the soil inventory which included fragile soil
areas (see DEIS, Appendix C, page 123).
15-9 There is no known research which quantifies loss of forest productiv-
ity resulting frcm incremental losses of topsoil.
16
15-10 Ihe vegetative composition which currently exists in the SYUs is
described in Chapter 2, Vegetation section. On page 70 of the DEIS,
it has been noted that vegetation oanposition in the SYUs would
change according to the level of harvest under each alternative (see
Table 3-8 and Appendices E and F). Species composition is not
expected to change, as indicated on page 71 of the DEIS.
15-11 The issue of separate management was not identified in scoping.
Therefore, it was not analyzed in the EIS. Also, see response to
comment 7-1.
15-12 See response to comment 15-6.
15-13 The average annual growth presently being added to the intensive base
for Alternative 9 is 5,165 MCF or 31.1 MM bd. ft. and to the
intensive and constrained base for Alternative 4 is 5,424 MCF or 32.7
MM bd. ft.
15-14 See response to common issue 3.
15-15 Impacts are expected to be insignificant to wetlands and aquatic
vegetation for all alternatives except Alternative 1. Refer to DEIS,
Chapter 3, Impacts on Vegetation, page 69 and to Appendix C, Table
C-4.
103
Umpqua Valley Audubon Society
P.O. Box 381. Roseburg, OR 97470
August 18, 1982
Mr. James Hart, District Manager
bureau of Land Management
777 N.W. Garden Valley Blvd.
Hoseburg, Oregon 97^70
Dear Mr. Hart,
The following Is our comment on the June 1982 Lraft Hoseburg
limber Management Environmental Impact statement.
The limber Management ols Is Inadequate In giving a balanced
range of alternatives. Alternatives 1 through 7 proposes to harvest
between 289 to 176 MMBF per year vs. Alternative B'r Alter-
natives 1 thru 5 are totally unacceptable from an ecological stan-1
point to maintain forest diversity. While the prescriptions proposed
In Alternatives 6 and 7 are not quite as far out of line, wildlife
and watersheds would only fair slightly better. Our claim Is evi-
denced from statements in the Dr.13 such as:
(a) Cavity nesters are predicted to "fall below self-sustaining
levels" In all but alternatives 6, 7 and 8 and "snag dependent wild-
life would be greatly reduced In the long term";
(b) "Planned timber harvest would so alter cover composition that
elk populations are expected to decline over time in all alternatives
except 8." And, "there are no long term provisions for retain!
mature or old growth forest beyond the fourth decade for survival
cover In this Important area and this absence could cause population
declines to proceed faster If severe weather occure
(c) Alternative 6, and not the preferred alternative, Is the only
option outside of Alternative 8, that would provide habitat for 25
or more pairs of spotted owls as recommended by the Oregon endangered"
Species lask Force under the previous 300 acre prescription. And
only Alternative 8 would provide a genetically viable pooulatlon
under the more recently suggested 1000 acre prescrlotlon.
We feel that Alternative 7. the tfo Herbicide, .io fertilizer Alter-
native, serves to further accentuate BLK's bias that forestry with-
out herbicides doesn't work, rather than trying to look for methods
that would generate some additional employment and would provide us
with a healthy, poison free environment.
-3-
16-1
16-2
The Ho Herbicide Alternative does not sufficiently address the
specific assumptions that allows the BLM to take allowable cut
credit for the use of herbicides, Manual release methods are
not fully discussed for which allowable cut credit should also
be received.
We feel strongly that Alternatives 1 through 7 provide a skewed
range of alternatives, shifted heavily to the side of maximum
commodity production. Yet BLM seemingly expects Alternative 8
to provide a balanced "extreme" to Alternative 1. Alternative
1 proposes to harvest 289 MMBF per year. The September 1981 Pre-
ferred Land Use Alternative document maintains that the district
only has the potential to produce 2?6 MMBF per year. Similarly
the DEIS preferred alternative's annual cut of 2^9 KKBF has been
Increased from September 1981 preferred alternative's recommended
harvest of 232 MKBF. Are these both suppose to be the same pre-
ferred alternative? Again, the cut has been skewed to one direction
with both Alternatives 1 and 2 proposing harvest in excess of the
prescoplng meeting's maximum timber harvest, Alternative A, which
proposed 266 KKBF. While the preferred alternative was Increased
by i4 MMBF and the maximum timber harvest alternative Increased
by 23 MMBF, Alternative 7 Is only 3 MMBF below the former Alter-
native C, and Alternative 8 Is only 5 MMBF below what was formerly
called D.
We realize that the various alternatives are for purposes of dis-
cussion and the number of assorted "timber first" proposals doesn't
necessarily insure that Alternative 8 will not be fairly evaulated.
However, if a "travel agent" were to open his briefcase and present
you with seven enticing vacation packages, all In seven states
east of the Mississippi River, but also happened to have a trip to
Colorado — although you may leaf through all the pages of the travel
brochures, no one really expects that the odds are you are going to
choose Colorado. If however, the travel agent wished to be sure
that the western part of the country was equally well represented
in your potential travel plans, It would behoove him to then also
have a few brochures from Utah, Montana or Wyoming.
Similarly, we would like to see a few alternatives In your draft
EIS package other than really only one that's on our side of the
river. If, for the analogy. Alternative 8 Is to the "west" and
Alternatives 1.2,3 etc. are to the "east", you have to admit that
If Alternatives 6 and 7 are "west" at all, then they're still drip-
ping on the shore where they Just barely got across the rlveri
Furthermore, Alternative 8 isn't nearly as far "west" as Alternatives
1.2, 3, 4, and 5 are "east". If you are going to have 5 alternatives
all In excess of 200 MMBF, then you can consider a few other alter-
natives less than 100 MMBF. If you wish to have an alternative,
such as number 1, which by your own admission Is 13 MMBF above your
potential to produce, then an analysis of the ecological Impacts on
16-3
16-4
16-5
elk and cavity nesters by only harvesting 50 MiBF, 25 tmaT, or
KKBF should also be considered. Alternative e would basically
only allow one population of elk (In the Tyee area) to hold Its own,
according to the draft ilS. Let's consider an alternative that
would maximize elk, spotted owls, bald eagles, cavity nesters and
anadramous fish In all areas of the forest. Only this type of
alternative would properly balance Alternatives 1 thru 5- In other
words Its O.K. If your travel agent wants to offer dream trips to
Bangor, Maine, but let's also have a trip to San Diego, California.
Alternative 8 doesn't get past Denver, Colorado.
Ihe "new" preferred alternative Increases timber harvesting by <*8
MMBF over the current annual allowable cut level, lo harvest this
timber, four Intensive management practices are employed — spacing
control In young stands, commercial thinning, fertilization, and
planting of genetically Improved trees. To Insure that future
timber management policies and practices do In fact "contribute
to the economic stability of local communities" as set forth In the
O&C Act, we ask that the F£IS fully analyze, and present documented
evidence that will demonstrate the feasablllty, and explain
degree of probability of success, before Intensive ia.iaieie.it 3.etno-s
las described are employed any more extensively.
Given a favorable market, It Is obvious that accelerated t:
harvest can produce a local economic "boom". We wish tne .-'Eli to
offer firm evidence that such accelerated harvest as proposed In
the preferred alternative, will not eventually result in economic
"bust". Our concern Is, that In meeting the Immediate timber demands
of this decade that both our economic and natural environments are
not "short changed" In future decades.
In a public appearance last year, U.S. Forest Service Regional
Forester, Richard Worthlngton remarked that certain Scandinavian
countries are facing severe timber shortages due to major miscal-
culations In their allowable cuts. Our total future timber supplies
should not be predicated on the assumed accuracy of allowable cut
calculations and high risk Intensive management techniques. If the
failure of any one of these techniques could leave us with an economy
below our minimal level of "stability".
Conservative, yet sound economic advise, Is to never Invest more
than you can afford to loose. High risk Investments often offer
the potential of paying the greatest dividends. But If an Investor's
"sure thing" stocks should go "belly-up" due to unforseen complica-
tions, then having a remaining nest egg safely tucked away In some
low Interest paying bank or S4L provides a basic level of security.
Our old growth forests are such a nest egg. It Is no wiser to
gamble on our future by liquidating vast quantles of old growth
In the next decade for the hoped for benefits of Intense "forest"
management, than It would have been for the Investor to have liquid-
ated his entire S&L account to assume the same high Intensive money
management risks.
104
16-6
16-7
16-8
2.
16-9
So before we. the members of the public, Invest anymore of our
old growth nest egg In your Intensive management forest Invest-
ment scheme, we would like you to more fully address some of the
basic forest Investment questions not yet fully dealt with In the
draft KIS - This way you can better demonstrate to us, your In-
vestors, that you are really wise managers and that you
have accurately accessed both the environmental and economic risk
you may be asking us to assume.
The EIS deals very little with the specific Issue of timber man-
agement despite Its title a nber Management"
EIS should address the ecological and financial feasibility of the
various Intensive management techniques as recommended In the pre-
ferred alternative and discuss the scientific basis by which these
methods would be applied.
The EIS does state that compaction from "dragging logs and operat-
ing ground-based logging equipment", "can reduce the vegetative
productivity of the soils by 10 to 25 percent" and "compaction and
reduced Infiltration capacity have been found to last at least 55
years (tower 197*0 and therefore may last longer than harvest rot-
ation periods." Also a general prescription Is given for high lead
I cable yarding vs. tractor skidding etc. Yet the ills seemingly re-
fuses to question or examine the Justifications for the present
methods of clear cut timber harvest and the associated machinery.
It Is as though the public Is to unquestionably accept that the
BLK applied methods and practices are always best, and the agency
should only have to deal with the Issue of how much timber harvest.
Instead of the additional Issue of the ways In which It Is accomp-
lished.
Different alternatives of timber harvest methods should also be
explored to evaluate the possibilities for reduced soil erosion
I and compaction. How would greater numbers of shelterwood prescrip-
tions reduce the need for shade cards, brush release, "post-treat-
ment surveys" etc.?
The Dais doesn't address these
told that "an environmental ass
dress the effect of the harvest
this way the BLM avoids having
ltlmate scrutiny. As these are
also have a say to the methods
them. What may be the most cos
be neither the most cost or eco
by only dealing with these ques
major policy decisions are not
ysls or review.
sorts of questions. Bather we are
essment of a timber sale will ad-
method, yarding system" etc. In
their preferred methods face leg-
public forest, the public should
that are employed In harvesting
t efficient In the short run, may
logically efficient In the long run.
tlons on the basis of Individual E.A.
available for concerned public anal-
Page 68 of the DEIS states that "the chemical quality of surface
water would be affected by slash disposal." And "that only Alter-
native 8 would provide adequate protection for streams." Ihe EIS
I should further discuss the Impacts to the biological systems of
first and second order streams of Introducing "fnstream concen-
trations of ammonla-nltro«en and manganese" that "could exceed
recommended water quality stnndards."
3. The DEIS states, buffers "are expected to minimize herbicide
drift or accidental direct spraying of water bodies" and move-
ment of herbicides through soil is usually mi of
Inches or a few feet." Also, "some detectable amounts may reach
the streams", "due to pilot error", but "planned delivery techni-
ques would reduce or prevent spray from drifting Into i
The nature of these statements acknowledges that risks neverthe-
less exists, and all one can reasonably expect to do Is "minimize"
problems so they "usually" go as they are suppose to. xTet
know that on occasion open water bodies are sprayed, or the risk
I of herbicides carried In subsurface water does exist. To adequately
assess the Impact of herbicides, some statistical <>:. .Id
be given of percent error (avoidable or unavoidable) In herbicide
application. And what are the Impacts on the biological systems
so affected?
Also the DEIS mentions how "fast-growing hardwoods, such as red
alder or vine maple, overtop and suppress slow-startlnf conifer
seedlings". Yet there Is no discussion of how broad leaf trees
or shrubs might aid the growth of conifers by providing shade on
southern exposures. Also there Is no Information on the contri-
butions of nitrogen-fixation by various species, although studies
have been done in southern Oregon and quantifiable data exists.
Fage 76 of the DEIS says "dlesel oil Is sometimes used as a carrier
for forest herbicides", "however, data are Insufficient to predict
the Impacts of dlesel oil carrier on animals In the EIS area.'
on page 87 you state, "phenoxy herbicides as applied do not affect
birds or eggs unless dlesel oil is used as a carrier." Based on
this last statement It seems that it would be reasonable for the
EIS to consider there Is a potential for an adverse Impact on avian
life as spray operations normally coincide with spring breeding
bird activities. What levels of phonoxy herbicides with dlesel
produce adverse effect on birds and their eggs? How does this com-
pare with herbicide treatments applied In the field?
Science deals In probabilities. While the BLK currently uses herb-
icides approved by the Environmental Protection Agency, based on a
scientific body of evidence that maintains that herbicide use does
not present any unacceptable human health risk, there also exists
a certain scientific body of evidence that phenoxy residues do blo-
accumulate, do move through the soil via leaching, do cause mut-
ations and cancer and are toxic In lower than measurable amount::.
Therefore, speaking scientifically, we can neither say that herb-
icides are totally safe or totally dangerous. Given both confllct-
lnc scientific bodies of knowledge, we can only conclude that since
the EM currently approves the use of 2,4-D (supposedly based on
scientific evidence) as a defoliant, that there presently exist a
16-11
-7-
16-12
16-13
greater than 50 •' probability (to the extent there Is more evidence
for than against) that these herbicides, from a human health stand
point, are safe. The EIS should therefore address the fact that
there Is a least some lesser probability that herbicides, as they
are presently applied, are not safe. The FEIS should more fully
discuss that the level of risk therefore assumed unavoidably by
certain members of our population, may not be an acceptable level
of risk to these Individuals.
In a report by the Comptroller General of the United States: Better
Lata .Jeeded To Determine The Extent To Which Herbicides Should Be
Used On Forest Lands , U.S. General Accounting Office CED-»l-4b,
April 17. 19B1 It Is generally concluded that the question of ex-
tent of replacement of herbicide with non-herblclde treatments can-
not be settled largely because the BLK and Forest Service have not
kept adequate records of cost or effectiveness, or make comparlslons
among different sites to determine why certain methods worked on
particular sites. On page 51 it stated, "The agencies do not know
the total cost for the various methods used to carry out site
preparation and release work and cannot, therefore, reliably use
cost as the major determinant for selecting among alternative
methods." If this Is the Roseburg BLK's problem the FEIS should
explain so, and offer ways to begin developing this data.
'*. The Bureau explains that 200 lbs. of fertilizer per acre will be
used In portions of the forest with exception of Alternative 7,
but little data Is given to substantiate Its assumed benefits.
What are the impacts of forest fertilization? The FEIS should
16"14 address problems associated with the:
| a. problems of long term Impact to forest soils.
16-15' D * consequences of the runoff of nitrogen Into streams.
jc. Impacts on delicately adapted Improved trees.
|d. lack of availability due to worldwide energy supplies which
could get worse.
16- 16 1
16^7
16-18
What Is the per cent growth gain per acre fertilized and by what
research Is this substantiated that this technique will be success-
ful in Roseburg 1 s drier climatic regimes, particularly on south
facing exposures? Most fertilization experimentation has been done
on soils known to be low In nitrogen. Because of Roseburg* s low
rainfall as compared with the rest of the Pacific Worthwest, why
shouldn't we assume that nitrogen needs are less, as the lower
rainfall tends to minimize leaching- In fact wouldn't fertilization
actually Increase the soil moisture stress? Since Roseburg Is not
like northwestern Oregon, the BLK should produce research on soils
substantially similar to those proposed for this fertilization
program, before substantial increases In the allowable cut are
made, if a sustained yield Is predicated on the success of this
technique. It is our understanding that, pending further research,
the Forest Service made a decision not to take allowable cut credit
for fertilization even in northwestern Oregon.
Table 3-2 on page 66 estimates that in the next decade under the
16-19
16-20
16-21
preferred alternative, there will be an additional loss of pro-
ductivity on 7.872 acres of BLK land. 2,6^7 acres would loose
their productivity even under Alternative 8. (It seems Ironic
that these acres be considered part of what the BLK chooses to
call "Sustain Yield Units" (SYU's).) Ihe draft EIS states that
total loss of nitrogen from clearcuttlng and slash burning can
reach as high as 9". But for comparison BLK settled for an ex-
pected loss of b% nitrogen and phosphorus and a JyC loss of Calcium
and Potassium. For the four elements this would result In a total
loss of 6,86l tons in the next decade (Table 3-3)- Would placing
5603 tons of nitrogen fertilizer on 56.029 acres, at 200 lbs/acre
(under Alternative <*) , begin to make up for this soil loss?
If the allowable cut Is figured on the basis that the combination
of two or more Intensive management treatments (I.e. first fert-
ilizer then thinning) will double the rate of growth, and there-
fore permit a larger annual cut, what documentation Is there that
this sort of "piggybacking" will in fact produce the anticipated
extra Increase in growth? An analysis of any such assumptions
should be made in the EIS If the combination of two or
practices Is assumed to result In any greater growth than If only
one practice Is employed.
Under the preferred alternative 333,319 acres will result In
trees with a minimum harvest age (HHA) of 50 years. The FJS
should address If the benefits gained by harvesting trees at
this younger KHA, would outweigh the long term cost In loss of
superior saw timber found In trees In excess of lb.lt Inches dbh
were these trees not harvested before they reached greater matur-
ity. Also would such a policy be In compliance with the 04C Act's
requirement of providing "for permanent forest production"?
Ihe EIS states that "target stocking levels of 2^5 to 320 trees/
acre cannot always be achieved by the Initial planting." £ven
with "post-treatment surveys", of the Roseburg District's 391,100
acres of commercial forest land, how many acres are currently un-
stocked or under stocked? How will additional Intensive manage-
ment practices alleviate or contribute to this problem, If these
problems have not met with solutions under present practices?
Have any growth studies been conducted on Roseburg zU. lands to
show that these techniques are successful under your particular
set of environmental circumstances?
In terms of site preparation, what assumptions are being made that
a certain per cent of natural seeding will serve to make up for
stocking failures? It must be recognized In the EIS that with
the proposed rapid rates of cutting, that stands that provided
gratuitous seed will soon be gone. What assumptions are being
made as to how many units will require replanting? Is good site
preparation an assumption on which the allowable cut Is based? If
so, the EIS should analyze your site preparation problems.
-Jg-23 6 -li° what extent Is the projected Increase In the allowable cut
16-22
-9-
16-23
16-24
16-25
16-26
16-27
16
dependent upon the use of Improved genetic strains of trees?
The EIS should assess the probable success that can be expected
to be met given the Inadequacy of research that has so far
occured with their use. Also the EIS should assess If this Is
really a viable technique for Increasing production as the tree
Improvement programs, as required by Instruction Memorandum
0R-79-334. are at this time behind schedule.
One Justification offered by the Dais for "the eventual planting
netlcally Improved trees on 90 percent of the Intensive tlm-
nductlon base," Is that "maintaining a broad selection of
parent trees would ensure variability In genetic populations".
While this might Insure "variability" It can't replace the
specific genes of those tree species that were adapted to those
site specif iciocatlons. Also It Is offered that "bLi\ administers
29 percent of the total forest land's." Is this meant to Infer
that the other ?1 t can be assumed to provide natural stock? It
should be expected that adjacent land ownerships will also adopt
similar Intensive forestry practices.
We agree with the DiilS that until "the symbiotic relationships
between plants and animals that function In old growth stands"
are "fully understood" It Is Important to maintain "a representa-
tive range of the old growth forest and associated floral and
faunal genotypes." We take strong exception that "all alternatives
except Alternatives 1,2 and 5 would provide adequate representation
of the original old growth systems." This Is an Incredible state-
ment, when other parts of the DEIS acknowledge that most other old
growth dependent species will be reduced below viable, self-sus-
taining levels except for Alternative 8.
Special area designations such as ACEC s, RMV's and outdoor ed-
ucation areas will comprise no more than .7/-' of the forest under
any of the alternatives. The proposed old growth Bear Gulch MA
recommended by the Federal Research Jatural Area Committee, has
not only been dropped but Is not even mentioned In the EIS. Ihe
acreage of the proposed 480 acre Jorth Kyrtle RNA has been cut
In half. We ask that this acerage be restored to the full uncut
480 acres as It was previously represented by the BLr. and
recommended by Dr. Jerry Franklin and the Research Natural Area
Committee.
We take exception to the statement that the preferred alternative
Is consistent with Statewide Planning Goals number 4 and 5« Ihi
liquidation of our old growth as envisioned in the preferred alter-
native would not be "to protect" this "natural and scenic resource".
Slmilarily It would not serve "to conserve forest land for" old
growth "forest uses".
|4.5,t of the Roseburg BLM District Is in public domain lands and
subject to different laws. Ihe ownership is, in Itself.
Justification for true multiple use and wildlife habitat retention.
16-30
16-31
105
Under the Endangered Species Act of 1973 It t all
I departmenl 1 seek to conser-
species ind I - orltles
in furtherance of - ; s of this Act." lable 3 of th
.-.mary Broc ore can be
to enhance the habitat of
then propoj
land allocation, that would only serve tc mount
ting eagle habitat,
your "authorities in furtherance of t! -:t."
I-rotoctlng bald
additional h Lded to encourage at least s
reestabllshment of pr-vlous historical populatlc:
you assure,
inly small population. location foi
i.dll Ulini
their obligation
s that construction of ne
to harassment of wildlife and r ge carnivore
habitat witln one-half mile of these road
of roads mean more access by hm
is probable." Also, "Adverse Impacts to el^ would occur
78 you stated , "1 h
be affected only to the- extent that road construction cou 1
previously unaccesslble areas. itlfled
or qualified." If it con be "qualified" for ot
that it
why should' nt the same i, and thus
and endangered species? Also th
within eagle nest sho
alternatives, why is it unreason
more llkel; In the lone run If an alternative ot
were selected''
Ihe CEIS states that an "envlronm
. peolflc action,
la Dies known to be present on the sit
I measures to be taken." Ihls doe? not address t
ened on>' endangered species may very well not bi
ivlronmental analysis" (i.e. the plant is not in bloom) an"
I therefore inadvertently destroy
In western Oregon about 30 secondary hole nestln
pendent on 14 primary excavators to provl '
in which to nest ( Ihe .ieed For '..'lldllfe a-lt-t llv. -■ '■
On PL,, - ■■.anaged forest Lor,' In Western Cre- — . • - __.
"to manage primary excavators at the 5o ercent 1 v.]
? safe level) requires two
"only Alternative 8 reaches I 1 svel alt--.
Alternatives 6 and 7 ercent
lent level accord to Table 3-10.
be to liberal, as the old Alter:.
was within 3 and 4 KH3I of Alternatives 7 and 6 was previously
described to offer only "a cavity dweller population at 40 ■ of
maximum potential throughout the District". According to Jack 16 - 32
rhomas, 'lldllfe Habitats In l.anaged Forest , 40: is the
very bottom of the "viable" range. Ihls level of cavity nester
population would be dangerously close to not being able to main-
tain self-sustaining populations. We therefore can not feel com-
fortable In your conclusion that Alternatives 6 and 7 are "close"
enough, especially when "District surveys regaled that snags and/
or wildlife trees are being provided at the rate of 0.1 per acre
on recent harvest units."
-cent Solicitor's review has stated "that the OiC legislation
is a conservation measure requiring a form of multiple use manage-
ment" and "further, the Act clearly does not mandate exclusive use,
but Instead requires management for other Interest as well as tim-
ber supply." The Law of i.arch 29. 1944 further solidifies 3L;.'s
commitment to multiple use management. Ihls lav; provided the Sec-
retary of Interior with the authority to set up cooperative sustain-
ed yield units to among other things "secure the benefits of forest
in. . .preservation of wildlife..." (16 U.S.C. 583) Yet In recom-
mending the protection of only 18 pairs of northern spotted oi
to be maintained (under the 30C "cro prescription) of the 55 pairs
known to presently occur on the district, BLM has ione an
job at fulfilling It: oal to keep the spotted owl off I
federal endangered list.
lollcltor's : tes: "In the case of those areas of land
direct conflict in use will occur, the bureau may choose one
use over the other, provided It has analyzed its choice in the eon-
text of the principle goals of each Act and is satisfied that the
particular choice has not significantly encroached upon the overall
effect of those goals." pnrtment of Fish and
life has stated that Roseburg' s contribution to the Spotted Owl
Management Plan is essential in providing a connection that will
assure genetic vlablllv . spotted owl populations on the
coast and in the Case recommending less habitat (and
number of pairs) for spotted owls In your preferred alternative, 16—35
then was recommended be provided by the Endangered Species Task ,w ^
Force, you will be severiy Jeopardizing the viability of this
species. Any alternative which would reduce existing old growth
on the Roseburg District from 110,900 remaining acres to Just
28,400 in Just three decades is clearly a "significant encroachment
upon the overall effect" of this particular multiple use goal.
In Pabltat Diversity For Wildlife On 3LH nanaaed Lands In Western
Orejon (revised October 1981) It is stated that If 15,. of PL:.
lands were retained In mldage and old growth forest, minimum
habitat diversity requirement could be met. Yet out of Roseburg
eiLi.'s 424,000 managed acres, all totaled, less than 9f (38,000 acres)
would be provided as habitat, in the preferred alternative, for
species which prefer old growth areas — countlns scenic corridors
and marginally protected stream buffers. As this Is wholly un-
acceptable to us, :ore full; your
choice" and ssue of how these less lounts
of acreage '.rill "secur . Pits of for . . - tlo.n
lldllfe"?
address the follovln. question!
« on Ithe nortiurn spotte- : owl. What does t
ID OO | *, -.. (or
lack of it' with the Department of
recommendations of the En . -
:
. e shown the
r until
ot th"!
llity to "
i
rotation than th.
continually provl
16-3
.
er acr
acre?
f.e of
Iso
I
4
on i able ')-■ , '•...
Land (To '
native ■'■ .
1 thru result in
■
. 00 tons, o!
In our .:
llty prob: ,.
re sedimentation (13 out of 17);
temperatures (16 out o:
Sow can the SLi: claim that Alternatlv
nlflcantly less
tons/decade, a difference of 4,40? tonsl :iow can cal-
culate the difference t el of con-
fidence to enable your claim? Especla] ju concede
Le soils are found throughout th
that "these soils Include 3?. ranltic soils or other
soils that ntial for mass failure and 135,711
acres of soils on very stee 1th Inclusion of unsta
Us."* Yet the preferred alternative would commit 333.319
acres of commercial forest land to Intensive timber management
Ls totals 172.253 acres of unstable soils. If this is sub-
tracted from BLI.'s total acreage of 424,000, 251, 74^ acres of
stable land remains. This is interesting to cr the
262,436 acre timber base recommended under alternative 8 that
would still produce 84 ,.,-.3F per year.
106
-13-
16-36
16-37
and an additional 52.2**? acres to be managed under what Is
called "modified area control" — (which still permits timber
harvest In riparian buffers). Studies on I
District show that landslides In Tyee sandstone Increase-
•ibove the undisturbed forest rate following clenrcuttlng
and roadbulldlng (according to the DEIS). Yet according to the
BLl'.'s 5 year timber sale plan, "4600 acres of these soils, ldent-
18 fragile, would be harvested."
It Is ridiculous to assume that Alternative 4 will produce as
positive gains for fish populations in comparison with Alternative
8 — the letter, which by your figures, wouldn't even produce 1/10
the sediment load. Also "should design features fall, portions
of streams could be adversely Impact. Is their probability
of failure? Aj-._ the tons of sediments per decade for each alter-
native figured without including the additional Impacts of possible
failures?
Under "environmental Consequences" page 77. the author attributes
the impact of timber management on fish populations and discusses
the Importance of maintaining buffers to protect "the habitat of
aquatic Invertebrates, which are Important both as food for fish
and as Indicators of stream quality." "On lands administered by
BLK in the SYUs there are approximately 270 miles of streams that
support cold water fish." Analysis of the sample 5-year timber
sale plan shows that approximately "17 miles of stream that sup-
port cold water fish pass through or are adjacent to 77 harvest
units." The author falls to draw the obvious conclusion of what
additional affect stream warming will have on fish populations
under the preferred alternative. The conclusion on page 79 how-
ever states, "If it is assumed current fish populations reflect
conditions and harvest regulations over the past decade, then It
can be assumed that fish populations would decline under Alter-
natives 1 through 3 due to Increased teaoeratures and sedimentation."
"Fish would Increase In Alternatives 4,6,7, and 8 and remain the
same under Alternative 5."
It Is hard to see how they will remain the same under the No'
Alternative 5 "If It Is assumed current fish populations
(which are not high) reflect conditions and harvest regulations
over the past decade" and as explained on page 78, since Alter-
native 5 makes "no provision for riparian buffers" .. ."water
temperatures would increase greatly." On page 68, the forcasted
sediment loads of Alternatives 6 and 8 don't even come close to
the magnitude of other alternative's sediment loads. Including
ntlves 4 and 7. It is difficult to see how either Alternative
4 or 7 coul ted to provide fish populations that would do
anything but decline. It Is amazing that BLii thinks that a sediment
load of 281,300 tons (Alt. 3) will decrease fish populations, but a
a projected sediment load of only slightly less (272,800 tons under
Alt. 4), will Increase fish populations. On page 18 It states
Alternative 4 allocated the same acreage to timber as Alternative 3.
Also "management elements would be the same as Alternative 3" —
under which "fish populations would decline."
16-38
12. The SIS states that "Alter,, tl -ovldes temperature aal •
ror first order and larger str . ,-. -natives 1
removal of merchantable timber would reduce thi rieao of
buffers to provide adequate shade resulting In lncr
tures." Also "downstream shading do- Iflcantly lower
temperatures of streams warmed by upstrea . al.
1971)." Since the tons of'Sedlment Produced Through prop,.
In lable 3-5 Is only again slightly less for Alternative 4 than
Alternatives J and 5, why should „e not also assume that Alter-
natives 2, 3 and 4 will also raise stream temperatur ;iy
the data shows that the magnitude of this Impact will be even
greater In Alternative 2 than 5?
Also we would expect fish success to decline under the preferred
alternative because "oxygen concentrations In stream gravel may
continue to decline for several
flow through gravels Is restricted by sedimentation (.-all and Lantz
19&9)." And, "for this reason, Impacts on lntragravel oxygen in
the SYU's would be directly related to the change In sediment s
discussed above" ( pa^e 69).
Also this same sediment yield, which
the natural rate (undisturbed condlt
with roads (Fredrlksen and Karr 1979
any measurable increases In summer 1
research done by Denlse :;arr of the
you can't count increased low flows
increase In flows are going to be le
on the larger streams, and will be 1
uatlon of the larger streams.
to be "23 tl
Ion) in a patch cut waters!
)" , could absorb and contain
ow flow levels. According to
Forestry Science Lab in Corvallls,
as a benefit. Any hypothetical
ss than your ability to
ess than the year to year fluct-
13- Other research by Pedell, Everest and swanson at the pacific .iorth-
west Forest and liange Experiment Station have E "-uldellnes
for future practices that will best preserve and restore both physical
and biological Integrity in streams ecosystems" ( Fish Habitat and
Streamslde ,,anagment fast and Present ) . Four key structural com-
ponents are to provide "(1) large live trees In riparian zones, (2)
large snags, (3) large logs on the flood plain, and (4) large snags
and large organic debris in the stream." "Organic debris in streams
Increases diversity of aquatic habitat by forming oools and protected
backwater areas, serves as a source of nutrients and substrate for
biological activity, and affect sediment movement and storage by
dissipating energy of flowing water and trapping sediment."'
Alternatives, other than #8 would not provide these conditions.
Page 75 of the DEIS states that "management by modified area control
as proposed In Alternatives 2,3,4 and 7 would. . .substantially alter
riparian habitats."
Of the Hoseburg BLi'.'s 424,000 acres only 22,800 acres consist of
riparian habitat yet "riparian habitat is Important as 88 percent
of the terrestrial wildlife species in the area use it to some degree."
-14-
-15-
16-39
14.
16-40
Yet in seven out of eight BLK alternatives buffers are provided
only along streams (200 feet wide in most cases) that are third
order or greater. According to the DEIS this makes up only about
3 percent of the forest land base." An additional 12,150 acres of
small first and second order streams would only receive protection
under the Full Ecosystems Alternative, Alternative 8. In addition,
page 45 of the DEIS concedes, that even along 3rd order streams
"some of this has been altered by past timber management practices
and Is In less than optimum condition."
Oregon Administrative Rules, Chapter 340, State Water Quality
Law for the I'mpqua Basin and the Clean Water Act of 1972, as
amended, specify that no temperature Increases are allowed on
streams that are above 58° Fahrenheit, and federal agencies are
bound to that state standard. How will the preferred alternative
prevent temperature Increases when Table 2-5 "Severe '.later Quality
Problems" Indicates that 16 of 17 major streams in the Hoseburg
District already have "elevated water temperatures?" Sediment
yield or turbidity is limited to 10S Increases — how can full timber
harvest be allowed on first and second order streams with the
Increased possibility of landslides when roots die in seven to ten
years?
In the FEIS please provide some explanation of the allowable cut
calculation. What assumptions must be made to Increase present
harvest levels? If any assumptions are being made which lack
sufficient documentation, then the FEIS should explain the rational
for using these assumptions.
I What would be the cost-benefit ratio for various intensive manage-
ment practices If you did not take a credit for cutting existing
old growth, but rather figured the allowable cut effect (ACE) Just
assuming reforestation alone?
A risk factor should be figured Into calculating the allowable cut.
The FEIS should state what the risk would be for:
a. drops in biological potential due to fire or disease. (The EIS
should also describe what forest diseases presently exist on the
Roseburg District.)
b. drops in biological potential resulting from overly optimistic
projections of growth increase resulting from intensive management.
c. inability to carry out management programs because of financial
squeezes or contract failures. (If a key assumption of the allowable
cut calculation Is that sufficient funding and personnel will be
available for the lmpllmentatlon of the final decision, then the
FEIS should Include a list of priorities should funding fall below
the accustomed levels.)
Table 1-5, "Summary of Impacts", provides a somewhat distorted
picture of net Job losses. Besides being based on a set of
assumptions not fully explained in the DEIS, future employment
pictures might be more accurate if they were based on present
trends In the Industry for the entire southern Oregon area coupled
with the reality that the "building boom" days, facilitated by low
mortgage rates, are gone. Also, if Instead the per cent of total
16-42
16-43
16-44
Job losses from BLK alternatives were compared with projected
declines in all areas, a more accurate picture would be portrayed,
rather than to basically Just single out BLr.'s contribution.
Previous studies have shown that the southern Oregon counties
are net exporters of timber. Apart from the present recession,
as long as mill capacity is above supply, there will be Job losses
I in the timber industry. The FEIS you write should acknowledge
these facts and estimate what the Job potential would be If more
of this timber, presently exported, were kept cycling through
the local economy.
15- We find the discussion of Impacts on recreation ludicrous. The
DEIS states that "opportunities for such activities as camping,
hiking, fishing, hunting, nature study and slghtseelnj would be
degraded in some areas." Yet "clearcuttlng" somehow balances
this by providing "opportunities" for " olcknlcklng" , "using ORV's"
and"provldlng openings for scenic views." r.aking a clear cut to
provide a scenic view, would be like blowing a hole In the roof
of your living room, to better facilitate seeing the stars.
Furthermore, there are presently 12,000 acres of roads on the
Roseburg BLK. This Is presently more acres of roads than Alter-
native 5, the .io Change Alternative, would provide In acres of
old growth in Just a little over 20 years (see Table 3-9 page 73).
In addition the DEIS states "In Alternatives 1,2,3, & 4 road
building during the decade would be more than in the past decade."
It seems the ORV opportunities are going to be more than adequately
provided for in proportion to opportunities for hiking and nature
study In an aesthetlcly pleasing environment. Ihe DEIS's reference
to clear cuts providing "plcknlcklng" oportunltles does not deserve
further comment.
We also resent the assumption that "some visitors may relo-
cate to other areas where opportunities for desired experiences
exist." The point Is, at the rate we are manipulating and alter-
ing our forest and other natural places, there will simply be few
places left to go where the hand of man hasn't already marred the
earth. We disagree with the statement on page 81 that "Alternatives
2,3,4 and 7 would be satisfactory "In meeting the demand for hiking".
Especially when you lump the hiking experience with "horseback
riding and off- road vehicle areas and trails." Also, some horse-
back riders may prefer bridle trails that offer a greater aesthetlc-
ly pleasing experience than what can be afforded. In the above
mentioned alternatives, from a tractor road through a clear cut.
Our forests should be managed, but not exploited. We need to re-
move forest products to meet human needs, but not at the total ex-
clusion of all other creature's needs. Both house of Congress
recently demonstrated their concern by an overwhelming unanimous
reauthorization of the Endangered Species Act. We don't believe
that the American public, represented by our Congress, accepts
the management of our forest's resources by an agency whose manage-
ment direction openly Implies and reports the future degradation
of our wildlife, our watersheds, and our remaining old growth
forests.
-16-
Slncerely ,
Umpqua Valley Audubon Society aoard of Directors
107
0\ Qiyv%AMC^>j6U^v^x-^
Response to comments in Letter 16
16-1 No allowable cut credit is tak
manual release methods of vegetation control. Refer to DEIS,
Appendix C, Allowable Cut Effect, page 127. Also, see i
cannon issue 3.
16-2 Alternative 4 in the DEIS is tl
MFP preferred alternat. <■
difference in volume is the r
the allowable cut calculation.
16-3 Alternative 8 is the wildlife alternative which in
allocated for int t management |
Appendix C, Table C-2.
16-4 The Roseburg District Young Growth Management Cam
(available at the Roseburg District Office), add:
management techniques incorporated in the Roseburg D:
along with rationale, assumptions and lit i
gains associated with such practices are represented by DFIT (see
response to comment 16-20). Scheduled monitoring will examine
of intensive practices as described in the DEIS, Chapter 1, p ■
16-5 The harvest level for all alternatives is computed to be sustainable
for 400 years. Refer to DEIS Appendix C, page 127. Fish
recreation and other water dependent activities are expected to be
sustainable.
16-6 See response to comment 16-3.
16-7 See response to comment 5-1.
16-8 Timber harvest method alternatives and their influence on soil
erosion and compaction are discussed in detail in Chapter III 1975,
Timber Management Final Environmental Impact Statement, incorporated
by reference in the EIS
The silvicultural validity and cost effectiveness of clearcutting and
intensive reforestation vs. shelterwoods are discussed in a Roseburg
District study, "Use of Artificial Shade to Increase Survival of
Douglas-fir in the Roseburg Area" (Wert and Lewis 1977). This study
is available for review at the Roseburg District Office.
16-9 In the Roseburg SYUs first and second order streams are normally dry
except during peak flow periods. Nutrient concentrations following
slash burning will normally not exist during flow periods- therefore,
impacts to water quality are not significant. Also, see text revision
in FEIS, Impacts on water Resources, Water Quality section.
16-10 The Roseburg District has been monitoring herbicide operations for
several years. This includes testing a number of water samples. All
of the test results have indicated either no herbicide residue or
levels of herbicides well within set standards. Results are available
at the Roseburg District Office.
16-11 The statement on page 87 of the DEIS was in error and has been
removed from the FEIS.
16-12 Evidence examined by EPA in the 2,4-D registration
recently summarized by Frank Dost et al . (SQCATS
Court in Portland indicates no significant human health hazai
silvicultural application of 2,4-D. This finding has be
by Drs. Melvin Rueben and Ruth Shearer, both of whan believe that any
human exposure to 2,4-D, regardless of how smal the
amount, presents a significant hazard to human health.
16-13 Roseburg District has conducted several cost studies associated with
vegetation management practices. Data are currently being collected
for each vegetation management practice. These data are being used in
the new Vegetation Management EIS, scheduled for completion later in
1983.
16-14 Long-term impacts to forest soils were judged to be insignificant
because the nitrogen increase caused by fertilization will readily be
eliminated by plant adsorption, volatilization and microbial action.
108
16-15 See response to ocmment 15-7.
16-16 Impacts from fertilization on genetically improved trees are
presented in the DEIS Chapter 3 Impacts on Vegetation section page
70. No adverse impacts on genetically improved trees are expected to
occur
16-17 Same recent forecasts indicate that energy supplies may be abundant
for years to come.
16-18 The Regional Forest Nutrition Research Project has been studying the
effects of forest fertilization in southwest Oregon for over 10
years. There are seven study plots in the BLM Roseburg District. This
research project is being conducted by the Pacific Northwest Forest
and Range Experiment Station and the University of Washington.
Results of the study indicate that cubic feet/acre/year increases in
tree growth commonly exceed the 11 percent gains in the district's
allowable cut model. Additional information is available at the
Roseburg District Office.
16-19 Fertilizer application, according to the district's management
regime, would not replace the volume of soil nutrient loss from
clearcutting or burning; however, fertilization provides an average
timber volume increase of 11 percent over natural production yields.
Thus, overall soil productivity is increased over natural levels
through fertilization.
16-20 The concept of "piggybacking" intensive practices ia controversial.
This controversy steins from a lack of research on the cumuli
effects of applying various combinations of intensive practices to
stands of varying site quality over the length of a harvest rotation.
Although long-term research is lacking, research of shorter duration
has produced much data. The authors of DFIT feel that data I - i
short-term research can be safely extrapolated into the future. (DPIT
is the managed Douglas-fir stand yield simulation model developed at
the USFS Pacific Northwest Forest and Range Experiment Station to
project future growth under various intensive management schemes.)
In developing the DFIT model, the best available information was used
to simulate the combined effects of intensive practices. BLM has
adopted DFIT, with certain adjustments, as an acceptable estijnator of
future managed stand yields. Also, see response to common issue 3.
16-21 Refer to DEIS, Appendix B, Table B-8. The analysis of differing
minimum harvest ages notes that under most conditions, the net
present value of the forest decreases with an increase in minimum
harvest age. Yields displayed in all alternatives are sustainable.
16-22 Two thousand two hundred twenty-six (2,226) acres of recent clearcuts
awaiting site preparation are currently non-stocked. Four hundred
sixty-seven (467) acres of brush and hardwood conversion areas await
initial planting. Five thousand fifty-nine (5,059) acres of partial
reforestation faUures are currently understocked. These
reforestation delays, as well as successes, are accounted for in the
"Reforestation Lag" time input to the allowable cut calculation.
Many studies specific to the utility of the proposed intensive
management practices on the Roseburg District are cited in the Young
Growth Management Committee Report (1979b). Additional local studies
attesting to the effectiveness of the practices are available in the
district office.
One hundred percent planting of harvested lands is planned.
Gratuitous seed from an adjacent source is not necessary to achieve
district goals but would certainly contribute toward reaching the
stocking standards if it occurred.
16-26 The Research Natural Area Committee originally identified the Bear
Gulch parcel as a needed cell for the western Cascades physiographic
province. The committee later indicated the cell was within the
Klamath Mountains or Siskiyou province, for which the Roseburg
District has no responsibility.
16-27 See response to comment 5-2.
16-28 BLM's conclusions regarding consistency with Statewide Planning Goals
were developed through consultation with Department of Land
Conservation and Development staff.
16-29 See response to comment 7-1.
Good site preparation and site maintenance are requirements of a
successful reforestation program.
16-23 See response to common issue 3 and comment 4-3. The Roseburg District
Young Growth Management Committee Report addresses the viability of
the tree improvement program.
16-24 BLM has made no assumptions as to reforestation methods on adjacent
private lands. Appendices E and F illustrate that BLM plans are not
going to significantly alter stand structure in the EIS area, as
related to the tree improvement program.
16-25 See revised text, FEIS, Chapter 3, Impacts on Vegetation section, for
a more comprehensive discussion of this issue.
16-30 The effect of the transportation system on State-listed species can
be quantified to the extent the given alternative provides protection
for selected owl pairs. The primary effect on the spotted owl would
come from harvest unit placement. Because road development is part of
an overall harvest action, roads are assumed to affect the owls in
the same manner as the harvest units when in proximity to owl
habitat.
With regard to federally listed species, i.e., the bald eagle, it is
assumed that compliance with the Endangered Species Act and the
development of Habitat Management Plans (on the lands allocated for
the eagle) will assure that no adverse conflicts between the
transportation system and the species habitat will occur.
109
16-31 Every effort, including appropriate season field examinations, is
made to become reasonably certain that there are no impacts to
federally listed threatened and endangered plants or those under
review for federal listing. Guidelines for botanical surveys are
given in Instruction Memorandum Roseburg 81-22.
16-32 As stated in the DEIS, Chapter 3, Impacts on Animals section, not
every alternative may provide habitat for all wildlife species in the
long term. Also, see response to cannon issue 1 and comment 12-1.
16-33 Based on the direction provided in the the new O&C Forest Resources
Policy (Appendix A), the BLM will not actively pursue a management
plan to yield any specified population level for spotted owls.
16-35 Conclusions on sediment yield for each alternative are compared
against the existing situation. Alternative 5 represents data
loped from the previous planning process, which is not
necessarily comparable with this plan. Based on
calculation. Alternative 4 is determined to ■ •rimental than
Alternative 5. However, the degree of significance and level of
precision are difficult to calculate with a high level of con!
16-36 The probability of failure cannot be precisely
properly designed and constructed pro:
failure. Specific practices are subject to char
xi mon
and results of new research. Th roth the DEIS
and FEIS does not address the possibility of design fail
An assessment of the effect this approach has on species viability
statewide is included in the FEIS, Conclusions section. Chapter 3,
under Impacts on Animals. Also, see response to comment 83-6.
16-34 The conclusions reached on page 79 of the DEIS, Table 3-6, are based
on changes in temperature and sediment compared to the existing
situation.
16-37 The text has been revised to indicate that a vegetative buff
be maintained in Alternative 5. In the EIS, Alternative 5 is
considered to be a continuation of the plan for the 1970s and a
reflection of the existing situation. Research by Hall and Lantz
(1969) indicates that increases in fine sediments to spawning beds
can decrease the permeabil ity of spawning gravels, af f^ -
survival of salmonid embryos and impeding emergence of fry. Increases
in sediments over the existing situation {Alternative 5) would result
in decreases in fish population, while decreases in sediment from the
existing situation (Alternative 5) would result in more favorable
habitat capable of supporting increased fish populations. Prom this,
it can be assumed that fish populations would be greater in
Alternatives 6, 8, or 9 than in Alternatives 4 or 7.
16-38 Buffers for sediments and for shade are two separate things. Shade
over third order and larger streams is provided in all alternatives.
Because Alternative 1 permits timber harvest in the streamside
buffers which would reduce shade, stream temperatures are expected
to increase under that alternative. Harvest in riparian areas on
first and second order streams is not expected to increase
temperatures as those streams are usually dry in the summer.
16-43 Yield projections for intensive management practices are based on
current research and are adjusted to operational levels. Yield gains
from intensive management practices are reduced to account for
physical variables which differ from controlled research and which
are below ultimate biological potential. These factors are bui
the allowable cut computation (refer to DEIS, paqe 127). Also, see
response to comments 16-22 and 16-23.
16-39 Chapter 340, State Water Quality Law, states that forest management
activities shall be in accordance with the Oregon Forest Practices
Act. Also, see response to comment 15-6.
16-40 The allowable cut computation process is discussed in the DEIS,
Appendix C, page 127. Prescribed management treatments are described
in the EIS, Chapter 1 and summarized on Tables 1-2. Also, see
response to common issue 3.
16-41 There is no allowable cut effect for reforestation alone. Refer to
DEIS, Appendix C, page 127 for discussion of the Allowable Cut Effect
(ACE) .
16-44 See response to common issue 2.
16-45 Table 2-17 of the EIS reports rates of change in lumber and wood
products employment for Douglas County, the regional economy
(Douglas, Lane, Coos, Josephine, and Jackson counties) and Oregon for
the period 1972-1980. The text on page 54 of the DEIS cites I
reports which make projections about employment in lumber and wood
products manufacturing. The FEIS displays the impacts on the human
environment of an array of alternate timber management programs
available to the Roseburg District of the Bureau of Land Management.
It is beyond the scope of the FEIS to evaluate alternative federal
policies on international or interregional log export.
16-42 In the event of a natural disaster, such as fire, blowdown, disease
or insect attack, the salvable volume harvested would be substituted
for the normally planned clearcut volume. No other safety or risk
factor is built into the allowable cut determination process.
However, if a disaster were extensive, a recalculation of the
allowable cut could be made before the normal 10-year recalculation.
i d States 1 >epartment ol the Interior
1202-03 (PNR-RE)
Roseburg Timber Management
DEIS
August 12, 1982
\A1 II IN \l PARK SI K\ II I
Pai iih Northwcut Region
32
Response to comments In Letter 32.
32-1 Ihis kind of analysis would be applied to Individual timber sales and
detailed in environmental assessments when such conflicts are
identified.
To: District Manager, Bureau of Land Management, Roseburg District
Office
From: Associate Regional Director, Recreation Resources and
Professional Services, Pacific Northwest Region
Subject: Roseburg Timber Management Draft Environmental Impact
Statement
Our comments on the subject document are provided below:
The proposed protection of cultural and/or historic resources is very
satisfactory. However, we have some concern about the way in which the
impacts on recreation are described. It is stated that "timber harvest
in the vicinity of potential hiking and equestrian trails would degrade
I the recreation experience ..." While this may be so, it might be
stated that if timber harvest is planned in the vicinity of potential
hiking and equestrian trails, attempts will be made to keep the impacts
upon the recreation experience to a minimum.
We realize environmental assessments will be prepared prior to each
timber sale and that these documents will provide more specifics. We
will look forward to reviewing the assessments.
Thank you for the opportunity to comment.
/£j*uL£ft£fc-
Richard L. Winters
33
-2-
^1 chard Chasm
P.r. Pox 51
Dlllard C=, 9TW2
16, Aug. 1982
Kr, Jim Hart, District .-.anager
Bureau of Land hanage:,
.,. Garder Valley Blvd.
Roseburg OR, ,: ^4 7 C
Dear Kr. Hart,
After several weeks of careful reading and study of the
. a-ao-eme-t Draft SIS, lifould like to submit the
following comments. I realize at the p-ese"t tltre we'dlscusslm th»
adequacy of this document to prepare the final 51? Borne time - ext year.
After years of nlar'lna document? from the county, stat<> a* 1
Forest Service, this BU. booklet Is quite refreshing. The olan'-lnu
effort and resulting text, I feel Is ge-erally to be commended fcr
presenting a series of choices and then honestly examining the co-Tllctn
that each choice entails. Ae- or» remembers the BLK of 5 or 6 years
Is clear you folks have come a lo"« way.
Since the final SIS will be the basis ror dec'sln^o we will
live with fcr ten Important years, a careful - 1 1 sous- lor of the facts
and full economic ;onsequences of cur decision Is -eccessarv. Whatever
qua: Draft EIS "s° there are als- several important
flaws *. Is oerfect, hcwever the I = =
are sr fundamental the average citlze' sould be misled eas!
This document displays a thorough grasp of the lustry
economy a-d the standard Justifications of that ecoroi «'■
economies of the forest other than logging are i"°s» r '^ the ~' r —
becomes vague a d the ha-dllna clumsy. Notice the of1 me -
Alturratlves 1,2,3,4, i 5. These are rea = ';»« of
subtly and variation the timber management eH of *
The remalnl g three alturn-i t' ves are cruno lump!) tn«t are dlff!
to divide Into their finer points that they might be
of the first five. While all oc"!fllctl g Points are wrltte' down, fie
overwhelmli.g bias Is to Increase the allowable cut. Thl = Is
surprising, It Is also displayed cor.slstantly , asal-- and ao-al- throutrhnut
this documert.
Basically this EIS plays off the money to be made clear
cutting against the birds and the bees a'd the f ' sh . As the "A
Oregon continues to emphasise the tourist attractions of this area the
monltary values of clear water, "^od fishing a>-d prist' »e vl=tas will
I be Increasing, Indeed such thloos are orlceles=. Yet ir this Draft EI?
■
tourism a-d the fisheries are grossly underestimated. Th-
33_2|Umpqua River Is not rated asVClas? I scenic area for exarrnle.
II ;- 1 far more sophisticated analysis of *
resources and their sccncmlc value, 'iuch a- analysis mlo-ht 'hew the
short term benefits of clearcuttlng are wiped out by the lor» term
value of old growth, the non-timber multiple uses and the co't of
loss of productivity due to erosion.
Another fundamental shortcoming of this document Is the
assumption that "Timber harvest under all alturratlves would be
accomplished predominately by clearcutt 1 ng . "
33-4
33-5
-3-
Few citizens object to the removal of trees, but cleareutti "<, will
be 3 -" ' il lie's rury. I ,,}■■
wasteful It the public's eye. Ar economic a -i )
high lead roeathods of clearcuttl ob versus cat loaai"r, ve-
logging lr, sensitive areas, versus the logins or sual] n lvate
citizens is not only deficient , It Is absent. the
value of old growth tln.ber 50 years fron; now as coir.nared to a ti
14 Inches In dlaneter, It might be qulfe foolhardy to clearcut every
il -g now. If It Is employment we seek, are altur-at've timber euttW
practices liable to put more Deople to work? This document cries for
a tter analysis.
It seems to me most of the conflicts of timber land u °* occur
on the same crou-d. Th= tourlts like the "ce-ery of the water, which
1 where the fish live ana where the riparian zo-ee 9r e r-u-- 1 a* well
as sensitive habitat. If meathods tcjextract logs from such ar-eas
without substantially altering the forest could te contracted «rti-
everyone cculd be accomadated.
| This brings ire to a final point. I would like to see the
33-6| alturr!atlves mapned out better. If they each have different acreaa
|l wculd like to see what 1 -- grig wl re are the various protected
areas and where Is the habitat to be protected by the differ' -b choices?
The E1K needs to realize that in ad-ntlor I rcvldlne l s=
for the mills they are also adjacert s for a lot of us a-d aor*
are coming. .Vhlle I do not want tc see local mills shut, flow" thi« 1°
no excuse to destroy America's legacy of natural beauty.
For the shade of a tree.
Richard Chasm
111
Response to comments in Letter 33
33-1 Estimates of sport angl n t for the Umpqua
Basin were provided by the (Oregon Dept. of Fish 1977
and Hassleman 1979). Estimates of recreational use of public lands
administered by the Roseburg District resulted from periodic
at both developed and undeveloped sites.
33-2 The North Umpqua River, although very high in sc . arxj a
designated state of Oregon Scenic Area, does not fit the critei
Class I scenery. It is categorized Class II (refer to DEIS,
for description of classes).
33-3 The economic effects of BLM-supplied fishing, hunting and outdoor
recreation on local employment, personal earnings and public 1
are evaluated in Chapters 2 and 3 of the EIS. The economic analysis
is limited to these resource uses because they are the only uses for
which reliable and regularly tabulated data exist.
33-4 See response to comment 5-1.
33-5 The economics of specific logging practices are considered in the
design of each timber sale.
33-6 M^>s are available for review at the Roseburg District Office for
those alternatives derived through the land use planning process
(Alts. 3, 4, 6, 8) as well as the new Preferred Alternative (Alt.
9).
43
UMPQUA COMMUNITY COLLEGE
THE COMMUNITY COLLEGE OF DOUGLAS COUNTY
IS "BUD" HAKANSON
President
Posl Office Box 967
Roseburg, Oregon 97470 0226
Telephone 440 4600
August 16, 1982
District Manager
BLM
777 NW Garden Valley Blvd
Roseburg, OR 97470
Dear Sir:
s recently come to my attention that you are proposing
to adopt a plan which would require a number of acres of
timber land to be immediately set aside to protect Spotted
Owls. As I understand it, the Alternate 2 Plan would still
aside 150,218 acres of old growth timberland.
I: loss to understand why that would not suffice
c )5 pairs of owls in our district. If you
divide 150,218 acres by 55 pairs of owls, you
2,731 acres per pair. If in fact that figure is cor.
I would recommend that you adopt Alternate 2.
This recommendation is made in light of our current
economy, and the fact that it is subject to review later
■ .
We need to get Douglas County back on the road to economic
recovery, and at the same time preserve the Spotted Owls!
Sincerely,
I. S. Hakanson
Response to comments in Letter 43
43-1 Alternative 2 would not set aside any old growth timber land with the
exception of that for bald eagles and what may occur on non-commer-
cial forest lands. There would, however, be ^proximately 150,000
acres of mature and old growth forest remaining after one decade if
Alternative 2 were selected and implemented, but the siz^ and
distribution of owl habitat may be comprcmised by unconstrained
timber management activities to the point where some habitat would no
longer support spotted owls.
President
ISH 3
SUN STUDS, INC. SUN VENEER DIV.
44
August 17, 1982
Mr. James Hart, District Manager
Roseburg District
Bureau of Land Management
777 N.W. Garden Valley Blvd.
Roseburg, Oregon 974 70
Dear Jim:
This letter is in response to your request for comments con-
cerning the D.E.I.S. for the Roseburg District Land Use and
Timber Management Plan.
Our general reaction to the Preferred Alternative is mixed.
We are pleased to see a proposed increase in the allowable cut
for the decade. We are concerned however at how this increase
was justified. Most importantly we are disturbed at the very
significant withdrawals from the commercial timber land base
for the highly questionable purpose of dedicating old growth
timber to spotted owls who may or may not need it. Further
we are concerned about directing substantial management efforts
toward this species when it is questionable as to what it's
biological needs are and secondly whether or not the species
really needs special protection in the first place. Because
of these concerns which we feel are inadequately addressed
in the D.E.I.S. we cannot support the proposed action.
One of the common inadequacies we have found in practically
all environmental impact statements is a tunnel vision con-
centration on the impacts of forest management as they relate
to the forest environment devoid of human influence. While
this approach certainly caters to the views of the preserva-
tionist camp, it does not address the concerns and needs of
our community and our country.
I This D.E.I.S. does address the concerns of the community to
some extent. It does not however address in real terms the
trade off of jobs and community stability versus preserving
old growth timber for a population of owls.
We are quickly learning in today's economy that our Nation
has drifted too far away from the efficient production of
basic goods and services that are necessary for human survival
and betterment. Do you think for example that the unemployed,
the poor people and the underfed people of this country and
the world really are that concerned about spotted owls?
Mr. J a me ■
August 17, 1982
Page Two
Our specific comments related to the D.E.I.S. fol j
Environmental Consequences pages 4-6
The author of this section obviously
proposed action as black as pot. ,ts such as
"changes in plant communities and habitat could
some plant species" and "there would be significant long-'
adverse impacts to some animal population certainly
I designed to alarm the reader. Since this plan only covers a
ten year planning period it would appear that these inflammatory
statements are out of line.
Criteria for Evaluating Alternatives page 14
It would appear that some of the criteria identified are
certainly more important to the selection of the preferred
alternative than are others. Surely providing local economic
stability must weigh more heavily in the decision making process
I than for example providing for Research Natural Areas. I believe
a grouping of these criteria by relative importance would
provide a better idea to the public as to how a proposed action
is chosen. It might even help the decision maker.
Comparison of Impacts page 23
In one short sentence on this page you have identified, probably
by accident the key concerns of this Impact Statement. It
reads "Two areas of major impacts are wildlife habitat and
economic conditions". My first reaction is which is the most
important, economics or wildlife habitat? Since the proposed
action raised the land allocation for wildlife habitat and
lowered the land allocation for timber management it is obvious
that the concern for wildlife habitat was the greatest. I do
not agree with this assessment, and neither do the vast majority
of people who work for a living in this county.
Environmental Consequences page 63-89
(A) Introduction
The concluding statement reads "A basic assumption of the
analysis is that sufficient funding and personnel will be
available for implementation of the final decision." For
the sake of our economic well being we sincerely hope this
assumption is valid. Judging by the experience of the
Medford District and their newly adopted Timber Management
Plan it is clearly a "high risk" that indeed funding won't
be available and our proposed allowable cut will fall as
monies for intensive management do not appear. Perhaps
this gamble should be discussed in the section justifying
increased allocation of land to wildlife habitat.
Mr. James Hart
August 17, 1982
Page Three
(B) Threatened or Endangered Plants page 71
The concluding statement reads "Therefore, environmental
analysis accomplished prior to any site specific action,
would identify any threatened or endangered plant species
known to be present on the site and appropriate measures
to be taken." If this process is properly followed it is
difficult to understand how "changes in plant communities
44 _ 4 ^ nd habitat could eliminate some plants." {page 5) (Emphasis
added) . Thus the elimination of some plants is not possible
or likely.
(C) Im pacts on Animals Terrestrial Vertebrates page 72
"Lyon (1979) and Perry and Overly (1977) have shown that
elk use is reduced within one-half mile of roads traversing
elk habitat." I would suggest that you make these studies
available for reading by the elk who frequently inhabit
the old Hinsdale Ranch pastureland adjacent to Hwy. 38
just east of Reedsport. These elk obviously do not know
that their behavior is nonconforming to current standards
set by Wildlife Biologists.
(D) Threatened and Endangered Animals page 78-80
In the final paragraph under Conclusions it reads in part
"The cumulative effects on the northern spotted owl are
difficult to predict as planning efforts,..., are just
beginning." "However, if other agencies and BLM Districts
do not provide for the recommended number then the species
would certainly be in danger and be considered for Federal
status regardless of the Roseburg decision." (Emphasis
added) .
Mr. James Hart
August 17, 1982
Page Four
We recommend a complete rewriting be undertaken with the goal
of eliminating the bias against timber management injected
by wildlife worshippers. The only viable alternative in our
view is Alternative #2 which should be identified as the
proposed action in the Final Environmental Impact Statement.
Sincerely,
SUN STUDS, INC.
Vice Preside:
RER:vf
cc : Douglas County Commissioners
44-5
We find this conclusion to be an incredible statement. In
the first place if you cannot predict the cumulative effects
on owl populations how can you say that the "species would
certainly be in danger" ? Secondly this plan only covers
a 10 year period at the end of which there will still be
140,000 acres of old growth habitat on the District. Surely
even the owls could still survive on only 140,000 acres.
This entire section indicates a paranoid approach to wild-
life management which we feel is completely uncalled for.
Nothing presented in this section justifies a 20, 000 acre
land allocation for the owls.
Conclusion and Summary
We do not support the proposed action chosen in the D.E.I.S.
Giving away a significant commercial timber land base for
the questionable purpose of saving a bunch of owls whose
population dynamics are still up for debate in our opinion
is a violation of public trust. Furthermore we feel the
proposed action is in violation of the O&C Act of 1937.
Response to comments in Letter 44.
A
47
113
Weyerhaeuser Company
44-1 See response to cannon issue 4.
P.O. Box 275
Springfield. Oregon 97477
AC 503 - 746 2511
August 18, 1982
44-2 The discussion on short-term impacts has been expanded in the FEIS,
Chapter 3. EIS procedures require an analysis which goes beyond the
10-year period to consider long-term impacts.
44-3 Refer to revised Appendix A, O&C Forest Resources Policy.
44-4 Present policy protects federally listed, proposed and candidate
plant species but does not provide protection for other species that
may be rare or rapidly declining in a single State (see revised
Appendix A). Also, see response to comment 16-31.
44-45 See response to common issue 1 and comments 11-8 and 43-1.
Rose burg Di stri ct Manager
Bureau of Land Management
777 N.W. Garden Valley Blvd.
Roseburg, Oregon 97470
RE:
We have reviewed and analyzed the Roseburg Timber
Draft Environmental Impact Statement (DEIS) and
following comments for your consideration in con
the final DEIS.
47-1
47-2
47-3|
We support the
to a few modi f
harvesting tec
Utili zing broa
where appropri
slopes under 3
basi cal 1 y cons
The BLM ref ore
page 121 do se
standards. We
harvested acre
intensive fore
al 1 acres with
have foun 3 i r
over the rot at
use of managemen
i cat ions. In Alt
hnique and age ;
dcast burning as
ate, and mechanic
5%; as wel 1 as th
istent with inten
stati on managemen
em to be out of 1
also quest ion wh
s would be schedu
st management sys
in a year of harv
useful to ha*
ion period of the
t Alt ernat I ve #4 (PA)
ernat i ve #4 , the pr i nc i pa 1
he sit
a primary source ,
1 site preparation I imi
e reforesta t i on targi
si ve forest management methods .
t cost s , how* J on
i ne with the accepted Li
y only 91.77, ot the annual
led for repl.int.ing sin. i
terns call for rev-
esting. Lastly, we
!:' splay
di strict .
Alternative 4 provides for approximately 18,300 acres of
buffers along third order and larger streams mana
modified area control. Harvesting in this area would amount
to an estimated 67„, of which only 11% would be by
Harvest of stream buffers should be consistent with the Oregon
Forest Practices Act. We do not support alternative #4 where
it requires buffers in excess of FPA regulations.
Bureau of Land Management
August 18, 1982
Page 2
Bureau of Land Management
August 18, 1982
Page 3
Alternative 4 calls for a 43,77
sive timber product ion base (as
situation). The majority of th
wildlife habitat management tec
reduction in the timber base,
other forest uses, requires the
"permanent forest production"
It is inconsistent to restrict
on federal land subject to that
I mandate . We recommend that the
cost/ bene fit analysis of its wi
consider more scientific input
Endangered Speci es Task Force i
ment .
9 -acre reduct ion in the inten-
in contrast to the current
t amount can be attributed to
hniques. We do not support a
The O&C Act, while promoting
BLM to manage its lands for
s a primary responsibi 1 i ty .
harvest of old growth t imber
legislated forest management
BLM do some type of
ldlife protection policies and
than si mply the Oregon
n terms of spotted owl manage-
47-5
In addition to support of a management al t ernat ive , we would
1 ike to comment briefly on a few points of management phi los-
ophy . On page 82 of the document we f ind , "most timber
management pract i ces .. .create visible contrast in the land-
scape. Assessing contrast for proposed activity can indicate
the severity of impact and help identify mitigation measures
to reduce the contrast and meet VRM class objectives for an
area . " And 1 ater we find "all publ ic 1 ands would be
managed in accordance with objectives to mitigate or in some
cases avoid impact of management activities on scenic values."
Nowhere do we find the rationale explaining why the BLM VRM
objectives are appropriate or should be met at all. The
proposal s for scenic area management are apparently based
on t he as sump t ion that only the old growth stand is aesthet-
LcalLy pi easing. In an area where timber is grown as a crop,
serving as a basis for our 1 ivel lhood , we believe there is a
need to redefine what is scenic . The broad mosaic of t imber-
1 and ages from old growth to second growth to fresh clear cut
should be viewed as natural and scenic . The current proposal s
for visual resource protection subjugate forest management
activity to a visual quality criterion which is loosely
defined and not consistent with the mandate of the O&C Act.
In regard to wildlife habitat management, throughout the
document are found such statements as the following:
Page 79: 'This long-term simplification (of stand struc-
ture) and loss of diversity would be significant
and adverse."
Page 79: (Snag dependent wildlife), "Alternatives 6 and 7
would support marginal populations while alterna-
tive 8 would provide for adequate numbers . "
Page 75: "...and 8 snag dwelling species would decline to
bel ow BLM target 1 eve Is in the 1 ong term. "
Page 73: "A situation exists as it is assumed that
habitats are currently at caring ca pa city."
Page 72 : "Once roads are closed to use, elk use incn
to near normal level s . "
Page 44: "Riparian zones are extremely important habitat
because they are used to a greater extent bv a
greater variety of species than any other
habi tat ."
Page 44 : "01 d growth forest s provide opt i mum h
a variety of animal spec i >
47-6
47-71
These statements imply a number of things
is a definite set of standards the BLM has e
del ineate good and bad levels of habitat mai
of the statements made above, however, have
the DEIS by actual direct documentation and,
misleading. Secondly, the inference f 1
the envi ronment is i nherent ly bad , is a bad
example , when a field of weeds i s t urned i nt
it is simplified but its habitat and food va
increased . Last 1 y, most forest management a
compati ble and beneficial to most wildlife s
exceptions are an important issue but should
bel ' e economic and forest management consi d
First, that there
-tied , whi ch
ntenati
ipported i n
there t
m p 1 i 1 i ■
as sump t ion. For
e 1 d of corn,
definitely
The
t be placed
•ns .
The DEIS recommends a cultural resource inventory on all acres
involved in ground-disturbing activities. We do not support
this act i on. federal law requires I ■ onl y
i n areas likely to con tain a significant cul tui r that
Lvities cease when such a site is discovered. To require
surveys on all lands is a very ex pens i ve and Inef fecti ve
Is of preserving cul tural resources . In any case, the
cost of those surveys shoul d be borne by the BLM and not its
licensees or contractors.
The O&C Act places forest production in the dominant
wi thin the scheme of the Bureau* s management of the O&C 1 ands .
Further, it is agreed that the act does not mandate exclusive
use but instead requires management for other intei
wel 1 as t imber suppl y . The Inclusion of management
for visual resources , exel us ive wi 1 dl i f e habitats and expanded
||4 Bureau of Land Management
August 18, 1982
Page 4
Response to conments tn ly
ripari an zones , we feel , has gone beyond the management need
for other forest uses and begins to significant ly erode the
dominant role of timber production on O&C lands.
Quincy ty. Pow. >
Vice President
Western Oregon Region
47-1 See response to cannon issue 5.
47-2 The acreage of initial planting ia equal to harvest area less roaded
area.
47-3 Harvest per decade in cubic foot volume would be constant for all
decades for all alternatives until regulation is reached.
47-4 See response to common issue 4.
47-5 Nowhere in the VTW system is it said or implied that only an old
growth stand is esthetically pleasing. Also, see revised Appendix A,
O&C Forest Resources Policy, and response to comment 58-2.
47-6 The following references are the basis for conclusions in the DEIS
regarding each specific comment:
Page 79 (simplification and diversity loss)
Thonas (1979) states that although even-aged management will
produce a mix of successional stages in the forest, the individual
stands have a low vertical diversity because of the comparative
simplicity of the stand structure.
Page 79 (snag dependent wildlife)
Page 44 (riparian zones)
Thomas et al . (1979) state that the lower the population level
managed for, the greater the risk of excluding a species from an
area. They continue by saying that management below the 40 percent
of potential population level may be too low to maintain
self-sustaining populations.
Thomas et al . cite several authors drawing the conclusion that
wildlife use riparian zones disproportionately more than any other
type of habitat.
Page 44 (old growth optimum habitat)
Page 75 (snag dwelling species decline)
Refer to citation of Franklin et al., page 44 in DEIS.
BLM wildlife program targets for cavity dwelling species seek to
achieve maintenance of viable populations thought to be at or
above the 40 percent potential population level. The analysis was
based on this premise.
Page 73 (carrying capacity)
The concept expressed is one generally accepted by practicing
wildlife biologists and used in this instance as a baseline in the
absence of specific population numbers.
Page 72 (roads and elk)
Harcum (1975) found that elk use following closure of logging
roads increased until it about equaled that on otherwise similar
unroaded areas.
47-7 The quantity and quality of the food and cover elements required by
forest wildlife is a direct result of the condition and arrangement
of the forest vegetation in space and time. In the long term, timber
management regimes which employ low minimum harvest ages (50 years)
and other intensive management techniques will lead to a forest
ecosystem with a significantly lower wildlife carrying capacity. This
decrease is a result of simplified vertical (within stand) and
horizontal (between stand) diversity, v#iich is a product of the loss
of stands 50 years and older. For species which depend upon stands in
excess of 50 years to meet their life needs, the impact is both
adverse and significant.
47-8 Costs of cultural resource surveys related to the forest management
program are borne by BUI.
50
August 19, 1982
James Hart, District Manager
August 19, 1982
Page Two
115
50-1
James Hart, District Manager
777 N. w. Garden Valley Blvd.
Roseburg, Oregon 97470
Dear Jim:
The purpose of this letter is to comment on the adequacy
of the Roseburg Timber Management Environmental Impact State-
ment (Draft) .
Review of the Environmental Impact Statement (EIS) reveals
serious deficiencies in the analysis of the Proposed Action and
the seven other alternatives. Also, the employment of SIMIX as
a forest simulation model to determine allowable cut levels will
yield results that are fundamentally deficient in economic consid-
erations.
The National Environmental Policy Act requires that the EIS
examine costs and benefits of the Proposed Action and other
alternatives . The EIS goes to great lengths to identify the
impacts to all aspects of the social and natural environment.
However, the actual costs implicit in the Propsed Action are
conspicuously missing. As an example, the Proposed Action contains
allocations of over 30,000 acres for Spotted Owl habitat. Old
Growth, and mature timber ecosystem preservation. After many
somewhat complicated calculations , one can determine from the EIS
that the setting aside of this productive forest land on 250 year
rotations will cost the region $9.5 million per year in gross
revenue and earnings and 287 jobs per year. Why isn't this signi-
ficant cost explicitly stated? More importantly, how does the BLM
justify this foregone revenue and employment? As a public agency
charged with managing the O & C lands for the benefit of the local
communities, the Proposed Action appears incongruent with your
objectives.
All of the alternatives presented in the EIS utilize SIMIX
as a timber harvest simulator. SIMIX is a most inappropriate
model for determining allowable cut levels on the Roseburg District.
The vast majority of the timber on the Roseburg District is over
mature. Managing over mature forest land under Sustained Yield-
Even Flow model (SIMIX) is an unsuitable means of carrying out the
legislative intent of the & C Act of 1937. The principle of
Sustained Yield should be interpreted as an overall objective;
to manage for continuous productive forest land. It should not be
interpreted as a command to manage the O & C lands in an inefficient
and wasteful manner. The scheduling of timber harvests under the
Sustained Yield-Even Plow model has produced a history of chronic
unemployment and economic stagnation in Western Oregon's timber
dependent communities. The Proposed Action will perpetuate this
situation needlessly.
ef\ nl The utilization of SIMIX fails to portray the actual costs
Ow ^| an d benefits of all alternatives, as required in the EIS process.
According to the EIS (Appendix, page 127) "SIMIX is not designed
to handle economic values or costs, 'and it does not seek out
alternative schedules or strategies". Therefore, the Sustained
Yield model (SIMIX) incorporates a zero interest rate into the
harvest scheduling process. The outcome of this blatant disregard
of economic criteria is evident in the forest simulation model's
objectives. The purpose of SIMIX is to calculate the "highest
sustainable allowable cut for each alternative", with a projected
period of 400 years to "assure that the condition of no planned
reduction in allowable cut can be met." Obviously, with a zero
interest rate, the cost to the local population of a harvest
schedule embodying a 400 year even flow level is insignificant.
However, what is the actual cost in real terms of unnecessarily
delaying liquidation of the BLM's over mature timber?
It is hoped that these comments will lead to a better
analysis and display of the costs and benefits of each of the
alternatives and an examination of harvest scheduling options.
Respectfully,
.kr-
K
Ralph Saperstein
1784 N. W. Estelle
Roseburg, Oregon 97470
Senator Bob Packwood
Senator Mark Hatfield
Representative Jim Weaver
Robert Burford
58
Response to conments in Letter 50
50-1 See response to common issue 4.
W LUMBER CO.
P. O. BOX 108
ROSEBURG, OREGON 97470 PHONE (5031 679-874
50-2 The comment refers not so much to SIMIX as to the policy on
non-declining even-flow constraint. SIMIX does not:
- inherently handle costs and benefits
- incorporate economic analysis or optimization
SIMIX is generally recognized as a valid model given an even-flow
constraint (refer to DEIS, Appendix C, page 127). The allowable cut
determination is based on a nondeclining harvest level over time (See
OfcC Forest Resources Policy, Appendix A).
August 18, 1982
Mr . James E. Hart
Roseburg District Manager
Bureau of Land Managemen t
777 NW Garden Valley Blvd.
Roseburg, OR 97470
Dear Mr. Hart:
This letter is in response to your request for input on the draft
Timber Management Environmental Impact Statement lor the Roseburg
sustained yield unit.
Roseburg Lumber Co. is highly dependent upon the Ros<
for its timber supply. We operate plants at li\ raphic
locations in Douglas County, which normally employ approxin
people. These facilities all draw wood from the Rob<!
In that our operations are extremely dependent on the federal govern-
ment for thier timber supply, any change in the allowable cut ha
tremendous impact on our future.
Roseburg Lumber also has a close historical relationship with tl
lands, in that the bulk of our industrial timbe:
with the BLM patchwork ownership. Because of this situation, Wi
very much concerned about the land use and silvi cultural recommend
contained in the various alternatives. Such
a direct and long te
administered.
Such programs will
impact on the manner in which our lanci-
rongly recommend the selection ol
is based on the iol lowing reasons:
In Douglas County , the wood products indus
provides jobs for more than 90% of the Coum
manufacturing employment . Becau
ship with si ' trade employment, anj
in the base wood industry employment has an amp
affect on the whole company.
The flow of O i C funds to various local government
agencies is critical in the maintenance and growth
of many key government servj
116
E. Hart
i 18, 1982
James E. Hart
Augunl 18, 1982
3. Under the O k C 137, the ro nues
from ,i ion both
from a congressional mandate, and in support of
local SOG i : , ruber
production as the dominant use on forest lands
admin Bureau of Land Management. The
law elling, cutting and
regrowing <>i timbei lominant use on
mi the objective of main-
ting a stable economic base for local dependent
communi tie
4. This stable revenue base is certainly not the cs
today in the local Douglas County economy. Industry
and communities throughout the Douglas County area are
reeling as the result ol the collapse of the national
wood products market. Although this is hopefully a
short term problem, a stable wood supply is critical
for any near term recovery.
5. Local industry is going through a transition, both
in terms of technology and wood supply. In the next
20 years, there will be a supply gap between the old
growth and second growth timber stands as indicated
Ln the Beu , which was part of the Forestry
Program for Oregon (published in 1977). During this
period, the need for a stable and re 1 i able timber
supply will be greater, in that the economy will be
quite f ragi le.
6. Although Alternative #2 "emphasizes timber production",
this management program more than meets the standards
that have been establ ished by various agencies relative
to the protection of the watershed, wildlife, and other
environmental and multiple use resource values.
During the decade of the 1970s, there was a period of experimentation,
both in terms of environmental and forestry management concepts .
Because of the avai lability of the forest resource, the philosophy
has been to hold volume in reserve in order to ensure that non-timber
resources were protected. As a result, the short term economic
productivity of these lands was sacni
Given the present economic situation, the clear mandate contained
in the & C Act, and the broader base of expertise that has been
developed over the last decade, it is now time for these lands to
contribute their full capacity to the needs of our community.
alternative 02 presents the proper compromise in meeting these various
object i \
1 .
58 1
58-2
58-3
We shai iti ting
a potentially uni-
ts a trade off i
in thi i < st land base. If the avail-
ability of these fund
probable in
I supply on an already str.i my would be
catastrophic .
There void in the dr;.
to the goal of proper coordination ob »ith
with other landowners and agencies (pages 26-27). There
is considerable discussion and analysis of management
techniques r< I directives and guld<
establ lshed by federal and state agencies . But there
is no consideration of the tremendous interaction
between the private/industrial landowner and the
Bureau of Land Management.
Given the patchwork nature of the k C land own*
the manner in which these lands are managed has a
significant impact on the adjacent landowner. This
interaction ef f ects land use , road access , and general
forest management. Although the bulk of Roseburg
Lumber Co. 's industrial forest lands intermix almost
in their entirety with the Bureau of Land Manat
ownership, at no time were we contacted relative to
the Impact of this plan on our operations, or the
potential impact on our management procedures on the
BLM ownership.
This lack of coordination is specifically illustrated
in certain land use catagorles. On page 83, there
is a list of areas that qualify for visual resource
management (VRM), and designated with high sensitivity
levels. In this category, logging and forest manage-
ment procedures are restricted in order to preserve
certain esthetic values.
In viewing the plan from a detailed standpoint,
the following points:
I would like to make
For example, one area
Reservoir. When this
by the County as a wa
understanding be1
the County . Existing
conducted as long as
Oregon Forest Practic
degradation to the wa
without any prior con
or County Planning st
additional zoning ove
timberland on the &
precedent for restric
of lands intermixed w
so designated is the Berry Creek
area was originally proposed
tershed, there was a very clear
small landowners, industry and
forestry practices would be
they were consistent with the
es Act, and did not result in
tershed. Suddenly, the BLM,
sultation to adjacent landowners
aff, has in affect proposed an
rlay. In restricting commercial
C, you have also set the
tion on the operational capaci ty
ith these holdings. A similar
James E. Hart
August 18, 1982
rQ olsituation is true on at least 30% of the proposed
OO v|areas contained on page 83. I would strongly
recommend that this superficial assignment of
management restrictions on lands intermixed with
commercial timberlands be reviewed. Roseburg Lumber
would be happy to provide detailed input in such
a process.
I hope, that in developing the final draft statement, the agency
will use common sense in establishing the appropriate balance
between various resource uses. In that the economic problems of
the Douglas County area are so obvious and so critical, the selection
of Alternative #2 represents the one sound approach in meeting the
needs of both the environment and the community.
Sincerely ,
ROSEBURG LUMBER CO.
Response to comments in Letter 58.
58-1 See response to common issue 2.
58-2 Of the visual resource areas listed on page 83 of the DEIS, forest
management activity restrictions are limited to BLM recreation areas
and State of Oregon designated scenic areas (segments of North Umpqua
Highway 138, Highway 42, 227 and Interstate 5)- Otherwise, mitigating
measures and project design features as described in the DEIS
provide for scenic values in such areas as Berry Creek Reservoir.
Allyn C. Ford
58-3 Management of intermingled private lands is controlled by State Laws
and local land use plans. Refer to DEIS, Chapter 1, pages 27-29.
BLM's preferred land use alternative and other alternatives
considered in the land use planning process were reviewed by the
Douglas County Planning Department. Tne Preferred Alternative is
believed to be consistent with Douglas County's Comprehensive Plan.
BLM visual management practices are not intended to set any precedent
for the management of intermingled private lands. Also, see response
to comment 4-4.
68
DOUGLAS TIMBER OPERATORS
Suite 222, Pacific Building
Roseburg, Oregon 97470
August 18, 1982
117
land to constrained timber production. Th ;
Owl habitat, old growth and ecosystem preservation thai
on artificially long (250 years) rotal
tion of the O & C grant land ront to th-
munities adjacent
Mr. James Hart, District Manager
Bureau of Land Management
777 NW Garden Valley Blvd.
Roseburg , Oregon 974 70
Dear Jim:
The following comments pertaining to the Roseburg Timber Managem-i;'
Environmental Impact Statement (Draft) are submitted on be hi
the Douglas Timber Operators . As an association representing local
t product manufacturers, loggers and retailers, with subs'
tial dependence on public timber supplies, our interest in planning
Cor the future management of local forest lands is acute. Over
l ? , 000 workers in Douglas , Coos and Lane Counties are norma lly em-
ployed by our members .
As we are all aware, the nation is experiencing the severist reces-
sion in decades. Local timber supply will have a profound effect on
the forest industry' s ability to provide prosperity and stability for
the area. Therefore, BLM planning decisions can hold the key to local
companies ' likelihood of surviving the current recession and thriving
once the economy turns around .
The Proposed Action, as described in the DEIS, has some serious short
comings. The PA designates 52,000 acres of prime commercial timber
68-1
In light of the nev. >m the Washington, D-C.
garding the selling aside of produi
timber uses, revision of the Proposed Actioi
cision to remove 52,000 acres from the Intel
base was derived from i
ledge. In addition, in 198J the Oregon State Lei
Memorial No. 1 . In this resolution thi
"make cor tain every possible effort is rr.^it t_ ^ p.- ..-.ser ve the in tens l ■■■■:-
management land base for timber production purposes" .
This statewide emphasis on preserving the land ba.-^e 1
• ■ t Land is not new. The Oregon Board of Forest .i
state position in its Fores try Plan -or Oregon. A ba
the progran is "to maintain the maximum potc;
base consistent with other resou-
quality". The Proposed Act ion is l no
Consequent ly , reductions of the managed timber land b-i
conflict with policy and objectives from the BLM headqu
ington, D.C., the Oregon State Legislature, the Oregon Board o*
local governments and the forest industry of Southwestern Oregon .
Another facet of the Proposed Action which deserves closer scrutiny
in the decision process is the heavy reliance on intensive management
to maintain allowable harvest levels. The Proposed Action will require
an increase in funding of approximately 42% to meet intensive manage-
ment object ives. While this increase may be feasible for the long-run,
it is unlikely for the short -run, considering current reduced stumpage
values and congressional unwillingness to provide supplemental appro-
priations. Your ability to carry out the proposed course of action may
be in serious jeopardy. Any reduction or elimination of cultural treat-
ments will in turn force a reduction in the al lowable harvest. A similar
situation in the Medford BLM District, where harvests had to be reduced
over 20MM, demonstrates the reality of our concern. The most likely
effect of the Proposed Action with its reduced land base and dependence
on intensive management would be to meet the harvest objectives .
Alternative 2 offers a much more viable and appropriate plan for managing
the Roseburg District. Alternative 2 provides for over 360,000 acres in
the Intensive Timber Production Base which is over 27, 000 acres more than
the Proposed Action. The addi tional increase in annual sustained yield
harvest of 18 million board feet will yield additional public revenues
and worker earnings. In addi tion, Alternative 2 would produce over 300
jobs more than the Proposed Action.
The benefits of Alternative 2 are achieved without sacrificing non-
timber resources and uses on the Roseburg District. Stream protection,
visual quality and wildlife habitat is enhanced with an al location of
24,786 acres. Alternative 2 will more than double the area designated
for recreation with respect to current conditions. Most important ly.
at the end of 10 years, over 140,000 acres of m« < : will
still be available for reclassification. This factor the op-
tion to provide adequate protection for the Spotted Owl and old growth
ecosystems, should continuing research deem permanent land alJor ■
necessary .
In order to provide scientifically sound analys : .
the DEIS, DTO has retained the services of two independent con;- i
firms. Dr. Robert Vincent has
draft. Ma. c on Bruce & Girard, Inc. has reviewed the ecom
in the DEIS. The results of the]
considered as part of DTO's formal input t<
Based on our review and the rep
that in the BLM to conn:
and local objectives t he Proposed Action should bo aband
and Alternative 2 adopted. The BLM will ha\
in your efforts to appropriately revise the Proposed Action.
Si net :
DOUG;
fi^jt^CL^T'
Lynn Herbert
President
118
AN ANALYSIS AND DISCUSSION OF THE WILDLIFE-FOREST ASPECTS
OF THE ROSEBURG TIMBER MANAGEMENT DRAFT
ENVIRONMENTAL IMPACT STATEMENT
Page
INTRODUCTION 2
ALLOCATION OF MATURE AND OLD-GROWTH ACRES FOR WILDLIFE .... k
ELK AND ROAD SYSTEMS 15
INTENSIVE FOREST MANAGEMENT AND WILDLIFE 18
RIPARIAN AREA MANAGEMENT AND FISHERIES 23
CONCLUSIONS 25
LITERATURE CITED 27
prepared for
DOUGLAS TIMBERS OPERATORS
Robert E. Vincent, Consultant
August, 1982
I INTRODUCTION
The Roseburg Timber Management Draft Environmental Impact Statement is a major
improvement over previously written EISs. Issues have been addressed, data
presented, and alternatives analyzed in a comprehensive manner. The Timber
Production Base is particularly important for, although BLM assumes funding
will always be available for intensive management, this may not be the situation.
By far the largest acreage in the SYUs is withdrawn from the intensive Timber
Production Base for wildlife habitat. A Constrained Timber Production Base
through Modified Area Control harvest has merit over no harvest; nevertheless,
acres allocated for constrained production should be examined carefully and
constrained harvest applied sparingly. This analysis focuses upon those wildlife-
land allocations that most reduce the Intensive Timber Production Base.
Subject areas emphasized in this discussion are (1) old-growth forests and
spotted owls, elk, and corridors; (2) elk and road systems; (3) intensive
forest management and wildlife; and (4) riparian areas. Generally, the analysis
shows that, for this planning cycle, allocation of old-growth forest need
not be carried out because a more-accurate, meaningful allocation can be made
later with greater information and no Individual resource will decline to
any extent in the meantime. Also, literature and common knowledge strongly
suggest that road impact upon elk use of habitat may be overemphasized. Broad
condemnation of the impact of intensive forest management on wildlife is not
justified, and the proposed riparian area management will adequately protect
and enhance the many uses of streamside areas.
hatchery fish have a role in the fishery, for listing MFP Withdrawals by use,
and for preparing a table of nonoverlapping resource allocation of forest
land.
One major weakness seems to be conclusion forming contrary to the supporting
and stated information.
The BLM is to be commended for proposing the concept of Area Control Harvest,
for considering a 250-year-harvest age of riparian and wildlife old-growth
blocks, for managing the Tyee Area with special consideration for elk, for
realizing the possible wildlife use of non-forest lands, for recognizing that
- 2 -
119
II ALLOCATION OF MATURE AND OLD-GROWTH ACRES FOR WILDLIFE
The Roseburg BLM Sustained Yield Units (SYUs) contain approximately 423,896
acres in total. As an example of how the intensive forest management base
is computed, Alternative 2 and Alternative 4 (Proposed Action) are examined.
Land allocated for Planned Timber Harvest under Alternatives 2 and 4 is reached
by designating acres for either no harvest or for constrained harvest.
Acreage Allocation
Alternative 2 Alternative 4
Total Acres
No Planned Timber Harvest
Physical Land Characteristi
MFP Withdrawals
Planned Timber Harvest
Constrained Base
VRM
Wildlife
Intensive Base
423,896
423,896
38,530
38,530
32,530
32,826
5,704
5,704
385,366
385,366
24,786
52,047
3,682
2,646
21,104
49,401
360,580
333,319
Thus, the difference of 27,261 acres between the Intensive Base Alternative 2
and the Proposed Action is the acreage allocated for spotted owls, old-growth
blocks, and 80-acre blocks, in other words, the acreage of mature and old-
growth forest for spotted owls and for old-growth corridors. VRM, bald eagle,
osprey, raptor, and riparian acreage allotments are all the same between the
two alternatives.
These constrained harvest acres of old-growth forest for wildlife, even with
limited harvest under Modified Area Control, remove 18 MM bd. ft. from the
annual timber harvest. Therefore, these 27,000 acres that grow 18 MM bd.
ft. are significant and worthy of evaluation as to why they are placed in
the Constrained Harvest Base. To illustrate the comparative magnitude of
impact of 18 MM bd. ft. on local employment and earnings in Douglas County,
18 MM bd. ft.
Timber Harvest
All Other
Resource Occupations
232
$ 3,072,600
99
$ 567,000
note the following:
Persons Employed
Personal Income
Three wildlife resource allocations comprise nearly all of the Constrained
Base: (1) spotted owl habitat, (2) old-growth blocks that are overlapping
or joint-use for all except 1,757 acres, and (3) 80-acre blocks that are nearly
all single-use designation (9,415 acres, single-use; 1,167, overlapping-use) .
A. Existing Situation
In contrast to some BLM Districts, the Roseburg District has large acreage
in mature and in old-growth stands. Also, the District has a comparatively
large spotted owl population. High amounts of these three permit flexibility
in the planning process.
1. Mature Forest. The SYUs contain 79,800 acres (202) in the 116-to-
195-year-habitat age class, while all lands contain 121,500 acres (92) of
mature forest.
2. Old-Growth Forest. The SYUs contain 110,900 acres (27%) in the 196+
-year-habitat age class, while all lands contain 234,100 acres (162) of old-
growth forest. Accordingly, mature and old-growth forest are not a scarce
habitat-age class but total 190,700 acres or 47% of the Roseburg District.
3. Spotted Owl Populations. Current census effort has found 55 habitat
units that each support a pair of owls, plus found 30 additional locations
in the SYUs where spotted owls have been found occasionally. In addition,
63 pair of owls have been recorded on other ownership within the planning
area. A total of 148 pair of spotted owls are known thus far to occupy habitat
within the EIS area. Of the known 55 habitat units in the SYUs, only 4 were
estimated to be in poor (less than 150 acres old growth) condition. Sixteen
of the occupied habitat units have less than 300 acres of old-growth forest.
Hence, 30% of the known locations supporting a pair of spotted owls in the
SYUs are doing so in a habitat unit smaller than 300 acres of old-growth forest.
68-2
The permanency of spotted owls in small habitat units is unknown, but they
are there and they have been counted with regularity.
B. Old-Growth Forest and Spotted Owl
Present status of the spotted owl population would have to be considered good
in the SYUs. The Proposed Action is to protect habitat fully for 18 pair
of owls, habitat that consists of a 300-acre, old-growth core plus an additional
900 acres with at least one-half older than 30 years. Through the 10th decade,
this action would maintain the prescribed pairs of owls. The relationship
between spotted owls and acres of old-growth forest is unclear. According
to Table 1-5 (DEIS), if 1,000 acres were a minimum-habitat requirement, the
spotted owl would not exist to the 10th decade under Alternatives 3 and 4,
notwithstanding that 31,800 of old-growth forest would be extant. Under Alternative
7, no owls would exist by the 10th decade even with 70,000 acres of old-growth
forest, whereas under Alternative 6 with 68,100 acres, 24 pair would be maintained.
These relationships are inconsistent.
68 3
No pro ject 1
are given for spotted owl populations at the end of the first
decade so extrapolation must be done from the acres of old-growth habitat.
The existing condition has a known habitat unit for each 2J300 acres of potential
habitat. Consequently, at the end of the first decade, all alternatives except
5 could be expected to maintain a minumum of approximately 35 pair.
Data on habitat requirements of spotted owl are limited and incomplete. Current
available data are solely from the research of one individual. Confusion
also exists between the original Oregon Endangered Species Task Force management
recommendations and the proposed revision of the Oregon Interagency Spotted
Owl Management Plan. Although the latter is only a proposal, not an accepted
or adopted revision, even as a proposal the revision was to maintain the option
of the additional acreage of old-growth forests for a 5-year period only.
68 _ 4|' Yet » this unadopted proposal is repeated and used several times in the DEIS.
Lack of data become awkward for the authors of the DEIS for it appears necessary
to inject frequent "weasel" words because definitive data are absent. A manage-
ment decision that impacts millions of board feet of timber harvest annually.
68 5
needs to be based on facts, not supposition. Phrases and words as "these
may be . . ."(p. 47), "in the opinion of the BLM district biologist . . ."(p. 47),
"applying extremely rough projections . . ."(p. 72), "assuming that these recommendations
. . ."(p. 78), "based on the assumption that . . ."(p. 79), "assuming," "indicates,"
"may be" (p. 80), and "the cumulative effects on the northern spotted owl are
difficult to predict as planning efforts by land management agencies are just
beginning . . ."(p. 80) express indecision. In addition, "no action would
be taken until habitat management plans are completed . . ."(p. 79) obviously
show habitat management plans have not been formulated for wildlife areas.
Given the necessity of using these many indefinite words, given the statement
that cumulative impacts on the owl are difficult to assess, and given the
absence of wildlife-habitat management plans, the logical conclusion is that
BLM needs additional planning time so that a decision of this magnitude is
not being based on guesses and assumptions.
The same indefinite phraseology is used to disguise lack of hard data on older
forest habitat: "the functioning of the old growth forest as a system, however,
has not yet been studied in depth . . ."(p. 42), and "there Is no definitive
description of the functioning of the old growth system and its importance
to long-range timber production"(p. 71) . Again, the need to guess is shown
by "habitat structure for all lands . . . cannot be accurately calculated"(p.44) .
Confusion of the role and amount of old-growth forests is further compounded
by the sentence on p. 71, "All alternatives except Alternatives 1, 2 and 5
would provide an adequate representation of the original old growth systems."
Yet after 10 years, the timeframe of this Timber Management Plan, there is
a IX difference in the acres of old-growth forest under Alternative 2 and
Alternative 3. In this situation where admittedly the function and importance
of old-growth systems are not well known nor the amount accurately calculated,
it is inconceivable that precise prediction could be made that Alternative
2 would not provide adequate representation while Alternative 3 with only
IX more old-growth habitat would provide adequate representation.
Replacement of younger forest with older forest is a basic premise of BLM
planning as shown by Alternative 8, 80-acre blocks of mature timber, the corridor
120
Led Area Control. Or BLM cannot squ.
the concept In their own thinking that old-growth forest is irreplaceable.
Irretrievably lost does not app I rowth forest. Thifl latter concept
is expressed tacitly by "old growth habitat that would be irretrievably lost
as long as those acres are managed im timber production . . ."(p. 72).
Certainly the implied idea is that whenever intensive timber management vera
stopped, old-growth habitat would not be irretrievably lost but would be reformed
as a natural consequence of succession and community development as expressed
on p. hi and p. 44. Moreover, if as assumed by BLM (p. 73) that habitats are
currently at carrying capacity, these new old-growth stands will support populations
of those species that prefer old-growth forests.
Thus to sum up, the best planning action for the spotted owl may well be to
take no action during this planning period for the following reasons:
(1) At the end of the planning period covered by this DEIS, over 70,000
acres of old-growth forest will remain in the SYUs under all alternatives
except Alternative 5.
(2) Spotted owl numbers are comparatively high.
(3) Confusion exists over minimum habitat requirements of spotted owls.
(4) The relationship between owl habitat and older forest is unclear.
(5) At the end of the planning period an adequate number of owls will
remain even without special allocation at this time.
(6) Lack of data on owls and their habitat necessitates the frequent
use of non-specific phrases.
(7) Habitat management plans have not been completed for SOMAs.
(8) The function and role of the old-growth system is unknown.
(9) Old-growth forest is replaceable and is a renewable resource
The spotted owl was classified as threatened by the then Oregon Department
of Wildlife on January 10, 1975, and no species have been added to or removed
from this classification since that date. At this time, other states and
provinces have not given the spotted owl special designation. British Columbia,
Washington, or California do not have specific management considerations for
the spotted owl, and owls have the same legal status and protection as all
other native nongame birds in these three states. The owl is not listed nor
I
has it been proposed for listing under the Federal Endangered Species Act.
"The species (spotted owl) situation does not meet the Endangered Species
Act of 1973 definitions of either Threatened or Endangered" (U. S . Fish and
Wildlife Service 1982 p. 24).
C. Old-Growth Forest and Elk
Elk are unevenly distributed throughout the SYUs with a concentration in the
Tyee Area of the Drain Unit. The elk population of 660 provides an average
annual harvest on BLM land of 54 elk and an annual expenditure of 2,738 hunter
days (Roseburg District PAA) . Over one-half of the harvest is from the Drain
Resource Area. As a result, elk hunting la a minor resource use in the SYUs
and needs to be viewed in prospective with dollars and people involved in
other resource uses.
The relationship between elk and old-growth forest is unclear and ill-defined.
If available, elk may well use old-growth stands; on the other hand, the requirement
of old-growth forests for elk survival is probably mainly a "smoke-screen."
To many, common knowledge examples exist of elk herds thriving in almost total
absence of old-growth forests: Tillamook Burn, Clatsop Plains, Millicoma
Tree Farm, etc. The real issue of elk habitat is obscured by the use of a
large, popular big-game animal as a surrogate for old-growth forest protectionism.
On p. 46, 73, and 74 (DEIS) mature and old-growth forests are designated as
necessary components of elk habitat. The essential ingredient provided by
these habitat types Is survival cover that is defined in the glossary In relation
to severe winter storms of heavy snow fall. Structure of mature and old-
growth forest provide thermal cover and limited food in close proximity. In
contrast to the glossary definition (p. 74), extreme summer temperatures are
considered part of survival cover.
Climate in the SYUs is temperature marine with warm summers and mild, wet
winters. Precipitation is mostly rain and "snow is generally short-lived"(p.32) .
Under such mild weather conditions, "extremely severe winter and summer weather
. . ."(DEIS p. 74) would occur rarely. Critical evaluation is essential If
resource allocation for extreme weather of a habitat type is needed so
68-7
seldom. An analogy could be made with an individual planting 100 acres in
wheat each year just in case the United States should have a famine. Each
year taxes are paid; seed is purchased; land is plowed and cultivated; the
crop is sprayed, fertilized, and finally combined only to be discarded because
the famine did not occur. Is survival cover worth the "just In case" cost?
The definition of survival cover for weather extremes is not precise. In
the DEIS, mature and old-growth stands are always both used as meeting the
structural requirements. Referring to 80-acre blocks of 120+ to 200+ year
old stands, "These stands will also provide the stand structure (canopy closure
and food resources) necessary to meet the survival cover needs of deer and
elk during severe winter weather" (MFP-NU-WL p. 11). So apparently mature forest
(116-195 years) will meet survival needs and old-growth forest is not necessary.
In addition, RAA-NU-WL (p. 18) stated about severe winter weather cover, "Stands
aged 50 to 200 years old will fulfill these needs efficiently, though older
stands, if present, are preferred." On p. 103 in the same document, the following
statement is written, "Although younger stands (80+ years) will provide summer
thermal cover needs for deer and elk, the stands aged 200+ years old are needed
to totally fulfill the animals' need for cover and emergency forage during
periods of severe cold, wet or snowy weather conditions." This statement
by BLM says (1) that 80+ year-old stands will meet summer thermal cover needs,
(2) that cold and wet are also a reason for survival cover, and (3) that the
objective is to totally fulfill all needs of the animals. Whether the stands
are 50+ or 80+ years old, these are far younger than old-growth stands. Also,
for an animal whose supposedly optimum habitat is Coast Range rainforest,
it is difficult to imagine rain being a problem. "Elk appeared indifferent
to average coast range winter weather . . ." (deCalesta and Witmer 1981 p. 38)
and furthermore elk used cover less on adverse winter days than on mild winter
days. Mandel and Kitcjien (1979) also saw elk often bedding or standing in
the open during heavy rain. To totally fulfill animals' habitat requirements
for all emergencies is impossible. The possibility of a more severe weather
event, a larger forest fire, a greater volcanic erruption, a new disease outbreak,
a more efficient competitor, a higher flood, etc., is always present. Habitat
needs for these rare contingencies cannot be totally met even with unrestricted
cost and unrestricted resource allocation.
I Thus, survival cover (summer and/or winter?) can be met by stands 50, 80,
120, or 100+ years of age depending upon definition and criteria used in the
DEIS. This highly specialized survival cover could be a possible essential
habitat element only under rarely occurring climatic events. Elk are not
hindered enough to move by snow depths less than 18 to 24 inches (Beall 1974,
Leege and Hickey 1977, Martinka 1976, Schoen 1977). Snow depths of this or
greater magnitude are rare and short-lived for southwestern Oregon.
Currently, 60% of Tyee Area is in 80-year or older forest habitat (DEIS p. 45).
Actually, whether elk must have or whether elk can do well without older forest
becomes a moot question with so much mature and old-growth forest. This is
recognized by BLM for "no impacts (on elk) are expected in the short term
. . ."(DEIS p. 79). Short term is defined as 10 years (DEIS p. 64). In addition.
Table 3-11 indicates that no change in elk population will occur in the second
decade either. Under any of the alternatives, elk habitat will not be changed
enough to impact elk. populations for at least 20 years.
In the Tyee "none of the lands scheduled for long rotation under modified
area control are located in this area. . . ."(DEIS p. 74). Then by comparing
Table 3-11 and Table 3-9, one Interprets that mature and old-growth forest
can be reduced by approximately 60% without changing the elk population.
Further support comes from Schoen (1977), who found that an elk herd in Western
Washington avoided old-growth stands in winter; from Harshman and Jubber (1980),
who found that elk survive during periods of heavy snowfall in the Western
Oregon Cascades in 80+ year-old stands; and from deCalesta and Witmer (1980),
who are cited as proof of requirement of old-growth forest. In fact of the
latter, the research year had only a trace of snow making meaningless a conclusion
that old-growth stands were essential to provide thermal cover and forage
under extremely heavy snow conditions.
Summer temperature relationships between elk and vegetation are complex, much
more so than air temperatures as measured by deCalesta and Witmer (1981) in
just the two temperature extremes of old-growth stands and recent clearcuts.
Elk, by their behavior, adapt to temperature (Beall 1976). They move less
in midday (deCalesta and Witmer 1981 p. 21, 31; Schoen 1977 p. 132) with a dally
121
activity of feeding morning and evening and retreating to cover in midday
(deCalesta and Witmer 1981 p. 37). Thus, high-midday air temperature in recent
clearcuts really have minor impact on elk. Not only may cooler mid- summer
air temperatures be found in old-growth stands but in younger-growth stands
as well. Second-growth stands may significantly moderate weather conditions
with the dense canopy reflecting solar radiation, thereby creating a micro-
climate more favorable for elk (deCalesta and Witmer 1981 p. 32, 35). Elk do
respond to air temperature. Respond is the key. Elk are intelligent animals
found over a wide range of topographic and climatic conditions. Normally,
they are not found at midday in midsummer in the midst of a recent clearcut
where air timperatures are 100-plus degrees F. (Pedersen 1976). On the contrary,
if old-growth stands, dense, young-growth stands, hardwood stands, or north
slopes are available, elk will be in the shade. The shade need not necessarily
be provided by old-growth stands.
As a result of the large acreage of mature and old-growth forest in the SYUs
and of the need to define habitat requirements more precisely, no immediacy
exists to allocate resources for elk survival cover at this time. Special
timber harvest regulations proposed for the Tyee Area such as smaller clearcuts,
distance to cover, cover width, road closure, etc., will enhance populations
in this significant elk area.
In conclusion, enlightenment is provided by the importance of the Tioga Management
Unit of ODFW to Roosevelt elk kill in Oregon. It is a "premier area as it
contributes an average of 51.5% of the Roosevelt elk kill, . . ."(in Oregon)
(RAA-DL-WL p. 21). This Unit also provides over half of the elk harvest in
the Dillard Resource Area. The same paragraph continues, "It should be noted
however that the bulk of the recorded kill came from lands owned by the Weyerhauser
Company and not those (BLM lands) within the planning unit." These private
forest lands that grew most of the elk were not mature or old-growth forests
but lands that had been clearcut over the past 25 years.
D. Mature and Old-Growth Forest Corridors
land allocated for corridors is commendable and has been partially successful.
The basic question is the concept of corridors. True, the habitat blocks
are "located in loosely arranged corridors . . ."(DEIS p. 124) or "generally
located within a corridor . . ."(DEIS p. 15). Still, 1,757 acres of old-growth
forest and 9,415 acres of mature forest are single-use allocations solely
for corridors. Comparing location of large blocks of old-growth forest with
location of spotted owl areas gives the impression that some old-growth areas
were chosen not as the best owl habitat but to fill corridor gaps.
Large old-growth blocks (approximately 600 acres each) are cited (MFP-NU-
WL p. 19) as a requirement for spotted owl, fisher, marten, and possibly cougar.
The fisher population level is at or near zero at the present time (RAA-DL-
Wl p. 41) and may have already passed from existence (RAA-DL-WL p. 95). Both
the marten (RAA-DL-WL p. 41) and cougar (MFP-NU-WL p. 19) commonly range broadly
across upland forests ranging in age from clearcuts to old-growth stands.
Only the spotted owl remains, and its habitat requirements have been discussed.
Elk are doing well under a fragmented forest-island habitat that the corridor
system supposedly would correct. From RAA-DR-WL (p. 19) the following sentences
are quoted, "The present distribution of elk in western Oregon is characterized
by population concentration centers which occur as islands across forest lands
of varying serai stages. The lack of elk in some seemingly acceptable habitat
has remained unexplained."
At this time the proposed corridor system is a test or experiment and as yet
an essentially unplanned experiment. Wildlife habitat management plans and
PAA analysis have not been completed for corridor lands. The option to form
a corridor system will never be foreclosed because mature and older forests
are renewable. Extinction is not an issue for no species in the SYUs are
found only in the Roseburg District or are threatened by extinction. During
this time of recession and budgetary restraint, a corridor system is a costly
experiment with little chance of fulfilling the intended purpose because of
the checkerboard nature of OiC lands.
Although it is presented in an off-hand, low-profile manner, apparently a
corridor system is envisioned for the SYUs. Attempts to overlap and joint-use
E. Summary of Old-Growth and Wildlife Acreage
What is sufficient old-growth forest to meet wildlife
eeds is not easily
68-9|
68-10
answered. The DEIS makes the statement (p. 74) that only Alternatives 6, 7,
and 8 would maintain, over the long-term, populations of animals whose optimum
habitat is mature and old-growth habitat. From Table 3-9 this would be interpreted
that currently enough is known about old-growth species to say that 100 years
from now 70,000 acres of old-growth forests will be required. The accuracy
of this long-term prediction based on the present scant data Is highly questionable.
Elk populations would only decline 20% (Tab. 1-5) in Alternatives 4 and 5.
Would this be past the population threshold and elk would cease to exist in
,the SYUs? Eighteen pair of spotted owl (Tab. 1-5) would remain at 100 years
lunder Alternatives 3 and 4. Is the spotted owl not then a good old-growth
|indicator species? From what is known it has larger and more stringent old-
growth habitat requirements than other species. According to the DEIS (p. 71),
Alternatives 3 and 4 would also "provide an adequate representation of the
original old-growth systems." Yes, prediction of habitat for wildlife populations
a century in the future is filled with possible errors.
Hence, whether for spotted owls, elk habitat, or corridors, there seems to
be little prudent support for allocating Commercial Forest Land to a Constrained
Timber Production Base for wildlife purposes. The amount of forest timber
harvest lost under the Constrained Base is significant. This EIS for the
Timber Management Plan "Is considered applicable for the decade . . ."(DEIS
p. 26). At the end of the ten-year period a more accurate assessment of wildlife
needs will be possible. Unreasonable demands have been placed on wild]
biologists the past five years to categorize and quantify wildlife habitat.
Studies of old-growth systems themselves have been recent (DEIS p. 42), let
alone studies on animals and relationships within the old-growth system. Many
of the guesses, best estimates, assumptions, district biologists' opinions,
etc., can in a decade be sound biological fact with resultant sound resource
allocation. Meanwhile, during the next decade habitat alteration will not be
extensive enough to harm knowingly any species or community.
Ill ELK AND ROAD SYSTEMS
Harrassment of wildlife (elk)by vehicles is at this time a confusing,
understood subject. Research does present conflicting results, but more impor-
tantly the visual experience of many people who regularly see elk along major
highways makes it difficult to convince the public that elk use is significantly
affected within h mile along each side of lightly used logging roads. The
following quotation from the August 8, 1982, Oregonian illustrates this point:
Tourists are getting an eyeful on coastal highways and b
this summer, as Roosevelt elk wade across the country scenery amid
farms and cattle.
The accompanying photograph, for example, was taken a]
U.S. 101, a mile south of Tillamook, where this four-point bull
has adopted a herd of young dairy princesses.
It's not common, but neither is it unusual, for elk bulls
to act this way, say biologists. The paternal instincts wear off
with time, as the elk realizes his adopted charges don't re
care about him one way or another.
The Reedsport herd has also been regularly hanging around
its usual field haunts alongside Oregon 38, a few miles east
town.
Wildlife biologists also seem to have a difficult time accepting elk avoidance
of habitat near roads. Hershey and Leege (1976) used truck and trailbike
to observe elk on eleven of eighteen observation routes and more recently
BLM and ODFW employees Smithey, Wisdom, and Hines (1982) conducted a study
on Roosevelt Elk and Black-tailed Deer Response to Habitat Changes Related
to Old-growth Conversion in South Western Oregon . The study was conducted
by road counts. If elk avoid using habitat near roads, roadside census techniques
would be highly inaccurate.
The scientific literature is conflicting. Studies rrass-
ment is significant are summarized by Irwin and Peek (1979), Lyon (1979),
Pedersen et al. (1979), and Perry and Overly (197(. the studies referred
to were on Rocky Mountain elk east of the Cascade Range where "topography
15 -
122
ili deap valleys and high steep ridges . . ."(Perry and Overly
1976 p. 62). In addition to larger topography, vegetation is more sparse In
these areas than in the Coast Range. For example, old-growth stands in Northern
Idaho had a visibility radius of 100 feet while second-growth stands had a
visibility radius of 40 feet. Hence, young-growth stands were used as hiding
cover more than other vegetation types (Irwin and Peek, 1979). Ward (1976)
concluded that "as long as the vehicle is moving, elk apparently feel relatively
safe"(p.38). In this particular four-year study In Wyoming, elk were seen
or telemetery located 44 times from the road to 200 yards, 34 times from 200
yards to 440 yards, 56 times from 440 yards to 880 yards (twice the distance),
and 57 times from 880 yards to 1760 yards (four times the distance). According
to this report, per amount of area, elk used area near the roads more than
area farther away. The conclusion of a study on roads and wildlife in Arizona
was "In late summer and fall, traffic increased significantly. However, it
is doubtful that this increase has an adverse effect on wildlife production
. . ."(Burbridge and Neff 1976 p. 56). Schoen (1977) found heavy use of roads
as travel routes in western Washington during the winter whether the roads
had been plowed or not and also stated, "Wapiti have frequently been observed
within 300 feet of a moderately used road, separated by cover, and appeared
to show little concern for vehicular traffic unless a vehicle stopped . .
."(p. 199). To continue from this same western Washington study, "on the whole,
especially in areas where dense vegetation provides cover and/or impedes travel;
it appears that wapiti will use low traffic or closed roads as travel lanes
or trails . , ."(p. 200). Shoen also noted that displacement movements by
current logging operations were usually one-half mile or less and that elk
were often observed within one-half mile of active logging when shielded by
vegetative cover or topography. Elk in Olympic National Park were observed
by Jenkins and Starky (1980) to bed often in spruce-hemlock stands within
audible range of human voices and traffic and appeared to be accustomed to
activity on the road.
be the most abundant habitat type on the SYUs in future yearn (DEIS App
Proper road and vegetation management would certainly narrow the impact zone
of roads on elk. "Losses to thlB cause (harrassment) would not be expected
to be large or significant to the population as a whole. . . ."(OBIS p. 72)
could readily be applied to the use of elk habitat and roads.
In brief, road systems may reduce elk use of nearby habitat under open, long-
sight-distance, high-traffic conditions. At the same time, smaller topography,
rapid revegetation, abundant hiding cover, and low-vehicular traffic permit
elk use nearer to road systems. Elk with a comparatively large home range
can easily move away from a road during periods of traffic or during the day
and then move nearer the road at night or low-traffic times to use the hat-
Not only do 13-to- 30-year-old trees provide hiding cover, but darkness (Pedersen,
1976) is also a ubiquitous reliable hiding cover. Besides being hiding cover,
darkness is also thermal cover as shown by the statement, "Elk used clearcut
areas at night but preferred the security and milder temperatures of dense
conifer stands during the day" (Edgerton and McConnell 1976 p. 5). Schoen
(1977) found that elk actually preferred open regions (clearcuts) at night.
Broad generalized statements that elk use is reduced within one-half mile
of roads and that up to 75% of an area would have reduced elk use because
of roads are extrapolation of data from a different elk in a different topography,
OO II In different vegetative types, and in different climates than the Coast Range.
Management of roads and of forest treatment practices and applying what is
known about elk behavior to a specific area (as the Tyee Area) can greatly
limit road-elk conflict.
Some interruption of normal elk behavior due to vehicular harrassment does
occur under certain circumstances. Pedersen (1979, 1979b) and Black et al.
(1976) have road management recommendations that are being incorporated Into
the Tyee Area to reduce conflict. Hiding and escape cover (DEIS p. 45) will
to significantly affect the stand or species compositio
Area"(DEIS p. 70).
of the entire Roseburg
IV INTENSIVE FOREST MANAGEMENT AND WILDLIFE
Intensive forest management is the basic premise of the Proposed Action: 249
MM bd. ft. from 333,319 acres of Commercial Forest Land compared to the No
Change Alternative with 201 MM bd. ft. from 390,984 acres. Wildlife and their
habitat will be influenced by intensive forest management, yet as a whole
the impact will be localized and will not be severe. Important habitat areas
for special uses or special species are protected by MFP withdrawals in all
alternatives except 5. Additional protection for other specialized uses is
allocated as Constrained Timber Production Base in all alternatives except
1 and 5. Not every forest management treatment will be applied to every acre
of Commercial Forest Land (DEIS p. 19), and as an example Alternative 2 has
63,000 acres that are not in the intensive timber harvest base. It is worthwhile
examing some of the forest treatments and the result of these treatments on
wildlife.
A. Slash Burning
Slash burning eliminates most live vegetation and associated animal populations
for a short time. Nevertheless, "this would last less than one growing season,
after which a vigorous growth of grasses and forbs would appear and animal
populations adapted to early successional-stage vegetation would be reestablished"
(DEIS p. 76). Forage for elk and deer is generally increased and woody material
that obstructs large animal movement is reduced. As a whole, burning impacts
are very short term with subsequent enhancement for important game species.
The trend toward spring or fall light burns reduces impact.
B. Artificial Regeneration
Artificial regeneration usually accelerates succession through early stages,
but since cutting will continue, other acres will be continuously beginning
early succession. A rotating source will be available. Impact is summarized
by "the artificial regeneration program on BLM-administered lands is not expected
- 18 -
68-12
68-13
C. Precommercial Thinning
Precommercial thinning is credited with increasing bird and small mammal use
but hindering deer and elk movement. Crouch (1974) is the reference cited
in the DEIS for the conclusion that slash impedes deer and elk movement. The
article is entirely on deer; the word elk is not even used so this reference
is not applicable to elk. On the other hand, Swanson (1970) does write that
sites with moderate amounts of logging debris generally received most elk
use and those with heavy amounts, the least use. Areas of patchy debris distribution
had more use than sites with uniform debris distribution. Whether or not
precommercial thinnings present a major obstruction to deer or elk would depend
mainly upon the pre-thinning density of the stand. Precommercial thinning
after trees are too large (15 years?) or on extremely dense stands (2,000
stems per acre) can restrict potential habitat use. Berg (1969) noted that
slash from precommercial thinning was quickly beaten to the ground and in
2 to 3 years the fine material is decomposed enough so that slash debris is
not a problem. Since only an average of approximately 11 of the SYUs acreage
would be precommercially thinned in any one year, it would not cause a significant
habitat impact.
D. Fertilization
Fertilization proposed at 10-year intervals with impacts lasting for an average
of 7 years (DEIS p. 70) will increase growth and palatability of many plant
species (DEIS p. 77). This will provide additional forage for wildlife and
will hasten the decomposition of thinning slash.
E. Commercial Thinning
Commercial thinning, between 30 and 60 years, that removes 30Z to 40* of the
basal area is discussed In the DEIS as resulting in lower deer and elk populations.
Edgerton (1972) and Edgerton and McConnell (1976) studies In northeastern
gg-14|0regon are ciced. Not all research has reached the same conclusion. Partial-
cuts were more acceptable to elk than clearcuts in western Montana (Marcum
1976); in northern Idaho, stands treated by shelterwood method produced nearly
123
as much herbaceous cover as clearcuts (Irwin 1976); in Arizona, selective
cutting increased understory vegetation for 11 to 15 years (Reynolds 1962);
in northeastern Oregon, timber stands with less-dense cover were used as forage
a.
areas (Pedersen 1979); In western Washington, elk during the summer used open
and sparse canopy habitat-types in the same proportion in which they occurred
while closed canopy habitats were avoided (Schoen 1977).
Thus, a total negative impact of partial-cuts on elk and deer is questionable.
The habitat type, the location, the climate, the adjacent land use and other
variables must be considered. Under many situations commercial thinning may
be more helpful than harmful to wildlife. The balance between forage and
cover habitats and available supply of both along with the ability of deer
and elk to move between habitats in order to maintain this balance is complex.
An overall negative influence upon wildlife Is not supported by existing biological
data.
An impact of commercial thinning upon selected birds is also indicated in
the DEIS. The authority cited is Franzreb and Ohmart (1978), a study in Arizona
that compared bird life in an area before and after logging. Before logging,
density was 896 trees per acre; after logging, density was 268 trees per acre.
Even though the total bird population was far smaller in the partial-cut area,
thinning led to an increase in tree-species diversity and no change in bird
species diversity. So tree thinning reduced total bird population but not
the number of bird species. In a study in New York where 25%, 50%, 75%, and
100% of the trees were removed by logging, Webb et al. (1977) concluded that
no bird species was eliminated by logging and that "numbers of species and
diversity indices were higher in logged areas and were positively correlated
with increased logging intensity" (p. 32). Areas with 25% and 50% tree removal
would be comparable to commercial thinning. Mauer et al. (1981) noted that
the difference in bird populations between a selective-cut area and a mature
forest was the addition of early-regrowth adapted species to the already present
mature-forest adapted species. The two-bird communitites remained very similar.
From another study the conclusion was "in summary, we found few differences
in the total density or richness of the breeding birds of a hardwood forest
that was affected by several forestry practices, including clear-cutting,
strip cutting, and thinning" (Freeman et al. 1981 p. 310). Obligate forest
birds had intermediate mixtures in thinned plots where thinning was removal
of 45% of the basal area. Szaro and Balda (1979) recommend that only 30%
of the basal area be removed to maintain and/or increase bird populations
in a Ponderosa pine forest.
Commercial thinning is also credited with Impacting nesting of Cooper's and
sharp-shinned hawks. Jactaan and Scott (1975) list seven out of ten sharp-
shinned hawk nests as being in young, even-aged conifer stands with single-
layered canopies while Cooper's hawks nested in Douglas-fir sjres with a mean-
stem density of 217 per acre. The latter density of 217 trees per acre (approximately
15 feet apart) is not a particularly dense stand. In fact, this af ter-thinnlng
tree density (approximately 200 trees per acre) is nearly the same den
used in the DEIS to Indicate that commercial thinning is harmful to accipiter
nesting habitat. Similarly, the other reference to indicate commercial thinning
harms bird habitat (Franzreb and Ohmart 1978) had an after-thinning density
of 268 stems per acre. The logical conclusion is that the thinned forest
habitat in the latter has more stems per acre (268) than the dense (as referred
to in the DEIS p. 74) habitat (217) in the previous reference. In other words,
density is relative.
Commercial thinning of 20% to 50/. of the basal area can alter forest habitat.
But as has been shown by the previous references, the impact may or may not
occur. It may be positive or negative. It often is slight. And it is species
specific, but overall does not eliminate species. Obviously, broad statements
that commercial thinning has negative impact are not supported by biological
evidence. Also, to be remembered is that on an average only approximately
0.1% of the Timber Production Base will be commercially thinned each year.
Intensive forest management treatments will, as a whole, not significantly
impact wildlife. Animals will temporarily compress or expand home ranges
and increase or decrease population levels over the short term as habitat
is available. Wildlife is adaptable and is capable of moving to avoid or
to use changing habitats whether the habitat is changed by succession or by
managed treatment. Two statements in the DEIS are worthy of note on this
subject. Intensive timber management practices will not^ eliminate hardwood
trees, shrubs, and herbaceous vegetation (p. 72), and "vegetation which is
disturbed or destroyed by timber management activities would eventually be
replaced by other plants of the same species and natural succession would
restore community structure until the next harvest stage" (DEIS p. 71). Therefore,
treatments may alter vegetation, but natural succession will return the same
species to the treated areas.
V RIPARIAN AREA MANAGEMENT AND FISHERIES
Riparian areas and their management as proposed under Alternatives 2, 3. <. ,
and 7 will adequately meet the many uses of the streamside acres. The 18,332
of riparian, plus 3,682 acres of VRM II, plus 2,772 acres for osprey and heron
provide 24,786 acres that are essentially riparian area. In addition, the
2,912 acres that are completely protected for bald eagle would also be mainly
riparian area. The small acreage proposed for clearcut and partial-cut would
not disrupt the integrity of the riparian system and its many functions while
still permitting multiple-use in the form of limited, regulated timber harvest.
Sediment would be trapped by the riparian areas under Modified Area Control
as indicated (DEIS p. 68), and no increase in stream water temperature would
be expected as indicated on p. 78. Forest harvest along first- and second-
order streams is cutting vegetation that is more like upland habitat than
riparian habitat (DEIS p. 75); hence, possible impact is lessoned.
Habitat improvements of various types as suggested in the MFP-Fisheries will
improve the instream fishery habitat and blockage removal will open new habitat.
Much of the low summer water flow is a result of domestic and agricultural
use over which BLM has little control.
6815
The summary statement on environmental consequences (DEIS p. 79) does not
to agree with data presented. Fish populations would be expected to dt-
under Alternative 1, 2, and 3 because of increased temperatures and sedimentation,
and under Alternativew 4 , 6, 7, and 8 fish populations would increase. In
contrast, the DEIS (p. 78) states, "Water temperatures would not increa
Alternatives 2, 3, 4, 6, 7, or 8 were selected." The difference in amount
of sediment between Alternatives 3 and 4 is only 3". With the current st3te
of the art, it is impossible to predict the influence of sediment upon fishes
with anywhere near a plus-or-minus-3'; accuracy.
23 -
124
68 16
In addition, the statement (DEIS p. 75) that the proposed management of riparian
areas for Alternatives 2, 3, 4, and 7 would substantially alter riparian habitats
can be questioned. Carefully controlled partial-cut (and other management
restrictions) on (>X of the total riparian acres and clearcuttlng of 0.072
annually could hardly produce substantial alteration on the whole riparian
area. The proposed riparian areas and their management under Alternatives
2, 3, 4, and 7 will maintain and enhance terrestrial wildlife, snag-dependent
species, water quality, streambank protection, and fish populations.
VI CONCLUSIONS
(1) BLM is commended for considering and applying some innovative management
and for the Improvement of this DEIS over previous Environmental Statements.
(2) Acres allocated for the Intensive Timber Production Base are of prime
Importance as the foundation of timber harvest.
(3) Acres removed from the Intensive Timber Production Base under all alternatives
except 1, 2, and 5 are major and significant.
(4) The SYUs presently have 47£ of Che area in mature and old-growth forests;
this acreage will remain high under all alternatives through the first decade.
(5) A comparatively high number of owls exist in the SYUs and will remain
high through the first decade.
(6) Much is not known about spotted owls and about old-growth forests with
the consequence that the relationship between wildlife and old-growth is unclear.
(7) The spotted owl is not listed nor has It been proposed for listing under
the Federal Endangered Species Act. In fact, the FWS says that the spotted
owl would not qualify for Federal listing.
(8) For the next decade, allocation of resources solely for the spotted
owl seems unnecessary and ill-advised.
(9) It has not been shown that elk must have old-growth forest as survival
cover. Because elk are adaptable, no decline in harvest is projected during
the next two decades.
(10) During either summer or winter, elk respond to weather conditions by
diurnal or longer movemenCs to locations that fill their temperature needs.
These cover needs can and often are met by habitat types other than old-growth
habitat.
(11) A proposed wildlife corridor system has little chance of functioning
because of the checkerboard nature of BLM lands.
(12) A corridor system is a costly and essentially unplanned experiment.
(13) For any of the reasons reported in the DEIS, there seems little prudent
support for allocating old-growth foresc to a Constrained or Non-harvest Base
for wildlife purposes.
- 25 -
(14) A generalized statement that elk-habitat use is noticeable reduced by
logging road systems is not supported by common knowledge nor by the literature.
Road harrassment impacts may be much less than presented in the DEIS.
(15) Intensive forest management may be either helpful or harmful to wildlife
habitat. Negative influence, if present, is nearly always short-lived and
localized.
(16) Succession will, over time, return Che same plant and animal community
to a management-treated area. As a result, old-growth forest is a renewable
resource.
(17) Acres allocated and management proposed for the riparian areas will
adequately protect and enhance the many important uses associated with streamside
and downstream areas.
LITERATURE CITED
Beall, R. C.
1974. Winter habitat use by a western Montana elk herd.
Univ. Mont., Missoula.
Ph.D. Thesis.
Beall, R. C.
1976. Elk habitat selection In relation to thermal radiation. I_n Proceedings
of the elk-logging-roads symposium, p. 97-100. Univ. Idaho, Moscow.
Berg, A. B.
1969. Thinning in precommercial stands.
Northwest, p. 79-87. Coop. Extension Ser
Woodland handbook for the Pacific
Oreg. State Univ., Corvallis.
Black, H. , R. Scherzinger, and J. W. Thomas
1976. Relationships of Rocky Mountain elk and Rocky Mountain mule deer habitat
to timber management in the Blue Mountains of Oregon and Washington. lr\
Proceedings of the elk-logging-roads symposium, p. 11-31. Univ. Idaho, Moscow.
Burbridge, W. R. and D. J. Neff
1976. Coconino National Forest — Arizona Game and Fish Department cooperative
roads — wildlife study. _In_ Proceedings of the elk-logging-roads symposium,
p. 44-57. Univ. Idaho, Moscow.
Crouch, G. L.
1974. Interaction of deer and forest succession on clearcuttings in the
Coast Range of Oregon. I_n Wildlife and forest management in the Pacific
Northwest, p. 133- 138. Oreg. State Univ., Corvallis.
deCalesta, D. S. and G. Witmer
1980. The relationship of stand development to habitat requirements of elk
in the Douglas-fir region of the Coast Range of Oregon. Final Report, FW-PNW-
Grant No. 18, 58 p. + tab. and fig., Dept. Fish and Wildl. , Oreg. State Univ.,
Corvallis.
Edgerton, P. J.
1972. Big game use and habitat changes in a recently logged mixed conifer
forest in northeastern Oregon. Proceedings 52nd Annu. Conf. West. Assoc.
State Fish and Game Coram., p. 239-246, Portland, Oreg.
Edgerton, P. J. and B. R. McConnell
gerton, P. J. and B. R. McConnell
1976. Diurnal temperature regimes of logged and unlogged mixed conifer stands
on elk summer range. USDA For. Serv. Res. Note, PNW-277. 6 p. Pac. Northwest
Vnr- 9nA D-inas Pvn ^f-n Pnrfl anrl Or«a
. range
For. and Range Exp. Stn
Portland, Oreg.
125
Franzreb, K. E. and R. 0. Ohnart
1978. The effects of timber harvest on breeding birds
forest. Condor 80:431-^11.
nixed coniferous
Freedraan, B., C. Beauchanp, I. A. McLaren, and S. I. Tingley
1981. Forestry management practices and populations of breeding birds in a
hardwood forest in Nova Scotia. Can. Field-Nat. 95(3) :307~31 1 .
Harshman, E. P. and R. N. Jubber
1980. Roosevelt elk and blacktailed deer guidelines for timber, recreation,
and road management. (Draft) 63 p. Willamette Nat'l. For. and ODFW.
Hershey, T. J. and T. A. Leege
1976. Influences of logging on elk on summer range in north-central Idaho.
In Proceedings of the elk- logging-roads symposium, p. 73-80. Univ. Idaho,
Moscow.
Irwin, L. L.
1976. Effects of intensive silviculture on big game forage sources in northern
Idaho, In Proceedings of the elk- logging-roads symposium, p. 135-142. Univ.
Idaho , Moscow.
Irwin, L. L. and J. M. Peek
1979. Relationship between road closure and elk behavior in northern Idaho.
In North American elk: ecology, behavior and management, p. 199-205. Univ.
Wyo. , Laramie.
Jackman, S. M. and J. M. Scott
1975. Literature of twenty-three selected forest birds of the Pacific Northwest.
USDA For. Serv. Reg. 6. 382 p. Portland, Oreg.
Jenkins, K. and E. Starkey
1980. Roosevelt elk of the Hoh Valley, Olympic National Park. Final Report,
Contract No. CX9000-7-0085, NPS, Oreg. Coop. Park Studies Unit. 32 p. Oreg.
State Univ., Corvallis.
Leege, T. A. and W. 0. Hickey
1977. Elk-snow habitat relationships in the Pete King Drainage, Idaho. Bull,
No. 6. 23 p. Idaho Dept. Fish and Game, Boise.
Lyon, J. L.
1979. Habitat effectiveness for elk as influenced by roads and cover. Jour.
For. 77(10) :658-660.
Mandel, R. D. and D. W. Kitchen
1979. The ecology of Roosevelt elk in and around Redwood National Park. 69 p.
Park Contract PX8480-8-0045. Humbolt State Univ., Areata, Calif.
Marcum, C. L.
1976. Habitat selection and use during summer and fall months by a western
Montana elk herd. _In Proceedings of the elk-logging-roads symposium, p. 91-96.
Univ. Idaho, Moscow.
Martinka, C. J.
1976. Fire and elk in Glacier National Park. In Proceedings tall timbers
fire ecology conf. No. 14:377-389.
Maurer, B. A., L. B. McArthur, and R. C. Whitmore
1981. Effects of logging on guild structure of a forest bird community in
West Virginia. Amer. Birds 35(1):11-13.
Pedersen, R. J.
1976. Pre-logging elk habitat use. In Proceedings of the elk-logging-roads
symposium, p. 85-87. Univ. Idaho, Moscow.
Pedersen, R. J., A. W. Adams, and J. Skovlin
1979. Elk management in Blue Mountain habitats. Report, Research and Develop-
ment Section, ODFW. 27 p. Portland, Oreg.
Pedersen, R. J.
1979a. Northeast Oregon elk research. Oreg. Wildl. 34(11) :3-5.
Pedersen, R. J.
1979b. Management and impacts of roads in relation to elk populations. In
Recreational impact on wildlands: Proceedings of a conference, p. 169-173.
USDA For. Serv., Pac. Northwest Reg., Portland, Oreg.
Perry, C. and R. Overly
1976. Impact of roads on big game distribution in portions of the Blue Mountains
of Washington. Jto Proceedings of the elk-logging-roads symposium, p. 62-68.
Univ. Idaho, Moscow.
Reynolds, H. G.
1962. Effect of logging on understory vegetation and deer use in a ponderosa
pine forest of Arizona. USDA For. Serv. Res. Note RM-64. 3 p. Rocky Mt. For.
and Range Exp. Sta. , Fort Collins, Colo.
Schoen, J. W.
1977. The ecological distribution and biology of wapiti (Cervus elaphus nelsoni )
in the Cedar River Watershed, Washington. Ph.D. Thesis. 406 p. Univ. Wash.,
Seattle.
Smithey, D. A., M. J. Wisdom, and W. H. Hines
1982. Roosevelt elk and black-tailed deer response to habitat changes related
to old-growth conversion in south western Oregon. Northwest Sec. Wildlife Soc.
Paper, presented in symposium on wildlife relationships in old-growth forests.
Juneau, Alaska.
Swanson, D. 0.
1970. Roosevelt elk-forestry relationships in the Douglas-fir region of the
Southern Oregon Coast Range. Ph.D. Thesis. 173 p. Univ. Mich., Ann Arbor.
Szaro, R. C. and R. P. Balda
1979. Effects of harvesting ponderosa pine on nongame bird populations. USDA
For. Serv. Res. Pap. RM-212. 8 p. Rocky Mt. For. and Range Exp. Stn. , Fort Collins,
Colo.
status review. USDI, FWS , Endangered Species
U.S. 7ish and Wildlife Service
1982. The northern spotted owl:
Program. 29 p. Portland, Oreg.
Ward, a. L.
1976. Elk behavior in relation to timber harvest operations and traffic on the
Medicine Bow Range in south-central Wyoming. In Proceedings of the elk-logging-
roads symposium, p. 32-43. Univ. Idaho, Moscow.
Webb, W. L., D. F. Brehrend, and B. Saisorn
1977. Effect of logging on songbird populations in a northern hardwood forest
Wildl. Mono. No. 55. 34 p. The Wildl. Soc.
Mason, Bruce & Girard. Inc.
Consulting Foresters
and, Oregon 97305
August 20, 1982
Mr. Robert E. Ragon
Vice President
Sun Studs, Inc.
P. O. Box 1127
Roseburg, Oregon 97 470
Dear Mr. Ragon:
This is our review of the Roseburg Timber Management Draft
Environmental Impact Statement. It contains our analysis based
on your request to examine the relative economic efficiency of
specific alternatives and possible intensive management funding
problems the BLM might face when implementing its preferred alter-
native.
We believe this draft environmental statement shows con-
siderable improvement over other BLM environmental statements
we have reviewed. The BLM staff at Roseburg was very helpful
in providing useful information and answering our requests. If
you wish we will be willing to answer any questions or clarify
any points for the BLM about our analysis.
68 17
Summary and Recommendations
1. Current low timber sale contract prices and delays in
harvest due to depressed wood products markets indicate the BWs
forecasted revenues in 1984, 1985 and 1986 are too high. Pro-
jected management costs may exceed 25 percent of such reduced
126
Mr. Robert E. Ragon
AuqUiit- 20,
Page 2
luction in
5 which support the hi el of
cut .
unmendation - The BLM should carefully potenl Lai
i 1 be aware of potent i
problems. Selection of Alternative 2 would alleviate this
possible problem by maintaining a larger land base.
2. A comparison of first decade management costs between
Alternatives 2, 4 and 5 show that the costs per MBF of harvest
are lowest for Alternative 2 . Also, we show that intens ive
forest management costs are a small percentage of the total
budget. A small change in the funding level could substantially
impact the intensive management program. Under the preferred
Alternative 4 such a reduction could cause the harvest level to
fall below recent past levels. This is not true for Alternative
2.
Recommendation - Select Alternative 2 .
3. The benefit/cost ratio of first decade management is
higher for Alternative 2 than Alternative 4. The effects of
intensive management are highly significant . Without intensive
management the Alternative 2 benefit /cost ratio would drop from
8.5 to 1 to 6.3 to 1. The intensive management program in Alter-
native 2 results in an increased annual allowable harvest of 89
million board feet. This would generate an additional $175
million in the first decade on an expenditure of about $6.6
68-18
Mr . Robert E. Ragon
August 20, 1982
Page 3
Lon. if funding for
an additional 176,000 acres of naturally grown forest wouli
needed to sustain the same harvest.
Recommendation - The intensive management program
critical part of any management program on the Roseburg District
and the funding necessary for implementation should receive
first priority.
4. The costs per acre for reforestation reported by the
Roseburg District are significantly higher than those of other
land managers in the area. Other costs per acre of management
practices are more in line.
Recommendation - The Roseburg District should institute a
program aimed at cost reductions on all reforestation activities.
5. The land base is very important as a basis for sustained
increases in harvest levels on the Roseburg District. Lands
proposed for management under an extended rotation must have 5
times more area to support a one million board foot annual harvest
level than under an intensive management regime. We recommend that
the BLM should use other means than extended rotations or use
rotations shorter than 250 years in order to provide for other
resource values .
6. The Soil Expectation Values {SEVJ contained in the
environmental statement were not used in selecting management
regimes, or if they were, other unstated criteria were controlling
selections. Also, we question some of the methods used and are
concerned about the implications of the low and negative values.
68 19
68 20
Mr . Robert E . Ragon
August 20, 1982
Page 4
Recommendation - The BLM should reexamine the purpose and
usefulness of SEV's in preparing the plan and limit their pre-
sentation in the EIS to a few critical values or regimes as they
relate to the final selection of management regimes. SEV's should
be determined with a 4 percent discount rate which gives greater
weight to more distant values and costs, thus reflecting govern-
ment ' s concern for future generations .
Financing Intensive Management
There is a critical relationship between forecasted timber
revenue and estimated timber management budgets on these O & C
lands. Management on O (, C lands is traditionally financed from
a share of the stumpage receipts. Furthermore, current federal
budget deficits are forcing agencies to place greater emphasis
on the efficiency of alternative investments in order to justify
expenditures regardless of source of funds. This situation is
further complicated by the fact that current timber sale con-
tracts are not being logged in a timely fashion due to the de-
pressed markets, and some may not be logged or will be extended.
Because of this critical relationship we are concerned about
preferred alternative which relies on intensive management
expenditures for maintenance of a high level of harvest volume.
Tabic B-2 on page 116 of the DEIS significantly overstates both
the revenue and cost levels that can be expected during the next
10 years. First, the forecast revenues for 1984 through 1987
appear to us to be too high. If one assumes an approximate 3
year lag between timber sale date and the harvest date, the har-
Mason Bruce ft Gm*»o Inc
68 20
Mr. Robert E. Ragon
August 20, 1982
Page 5
st values of $302 per MBF during 1984 are far too high. The
erage price of timber sold on the Roseburg District in 1981
was $259 per MBF and to date in 1982 the average price is $130
per MBF. These are the sales that will be cut and paid for
during 1983 and 1984.
Also, the harvest levels shown in Table B-2 overstate what
reasonably could be expected to be harvested during 1984 to 1986.
The BLM will not begin to sell its higher proposed allowable
harvest volume until 1984. Consequently, none of this increased
volume will be harvested until about 1987.
The estimated forest management costs shown in Table B-2
do not adequately reflect the actual acres that are to be treated
in the initial part of the decade. In particular, the increased
planting acreage shown by BLM will not be necessary until some-
time after 1987 when the increased harvested areas actually are
ready for planting.
We have made a revised estimate of sales volume and projected
revenues and costs in Exhibit 1. In our opinion these are more
realistic estimates of the sales volumes and values to be expected
during the next 3 years. Exhibit 1 also includes an estimate of
actual harvest levels for 1982-84 and two levels of estimated
harvest values per KBF for 1984-86. Based on these estimates
it is our opinion there is a possibility that 25 percent of the
receipts from timber harvest would not be sufficient to fund
the estimated forest management costs shown in the BLM Table B-2.
68 21
Mr. Robert E. Ragon
August 20, 1982
Page 6
As a result we recommend that the BLM more closely evaluate
potential income flows against estimated costs. Final plans
should provide for such a contingency in order to insure a con-
tinued high level of annual timber harvest.
Economic Efficiency of Alternatives
Forest management costs should be carefully examined in
relation to the benefits in terms of harvest volumes produced.
The BLM planning does not clearly present this relationship for
each alternative. We have displayed the first decade costs for
forest management for three of BLM's alternatives in our Exhibit 2.
The bottom line reveals that the management costs per MBF pro-
duced by Alternatives 2 and 4 are 6 percent less than those of
Alternative 5. Alternative 2 has the lowest per MBF cost and
by that criteria would be the best. Exhibit 2 also shows that
the major expenditures in Alternatives 2, 4 and 5 (other alter-
natives are similar) are for planting, replanting and sale preparation
and administration. These are basic activities and do not include
the intensive management costs of precommercial thinning, genetics,
fertilization, etc. In Alternatives 2 and 4, ninety percent of
the total management expenditures occur in these basic activities.
In contrast, 97 percent of the total management expenditures in
Alternative 5 (the present situation) are related to planting,
replanting and timber sale preparation and administration. The
intensive forest practices proposed in either Alternative 2 or
4 make up the balance of the total costs, or about 10 percent.
127
Mr. Robert E. Ragon
August 20, 1982
Page 7
This is a small percent of the total manag ires
required. Yet, these expenditures will generate a very substai
increase in the allowable harvest r
Economic Efficiency of Intensive Practices
Total costs and total revenues cannot be used alone to compare
the relative efficiency of alternative plans nor of forestry prac-
tices within plans. We have examined ncy using
benefit/cost ratios for only the first decade and have isolated
intensive management effects on the ratios. In a comparison of
Alternative 2 and the BLM preferred Alternative 4, we found tl
Alternative 2 had the highest benefit to cost ratio. (See Exh
3. ) Alternative 2 provides about $526 million in disco
decade revenue against discounted costs of $61 mil!.
ratio of 8.5 to 1. The BLM's preferred alternative would pro-
duce about $490 million in discounted first decade reve;
discounted costs of $58 million and a ratio of 8.4 to 1.
In order to measure the effects of intensive management,
examined Alternative 2 under the assumption that funds mi
not be available in the first decade to implement the planned
intensive forest management practices . These practices included
genetic planting, precommercial and commercial thinning and ferti-
lization. These practices require only about 10 percent of the
expected first decade costs in Alternative 2. But reduced stumpage
revenue early in the decade is a possibility as noted earlier.
If this should happen, a likely candidate for cost savings would
be the intensive practices. However , we would not recommend such
Mr. Robert E. Ragon
August 20, 1982
Page 8
action because of the critical and highly productive responses
to intensive management in terms of increased harvest . Our
analysis results in Exhibit 3 shows the impact of intensive
practices. Without these the benefit/cost ratio for the first
decade in Alternative 2 is reduced from 8.5 to 1 down to 6 . 3
to 1 . A similar reduction could be expected without the intensive
practices in BLM's preferred Alternative 4.
The great importance of the intensive management funding
is further illustrated in Exhibit 4. The annual harvest of
Alternative 2 is increased by 8 9 million board feet because of
intensive management. The benefit/cost ratio of the first decade
intensive management program is 26.3 to 1.
The impacts of the intensive management program on the
harvest level (often called the allowable cut effect) was
estimated because time did not permit use of BLM's SIMIX model.
We considered only the first decade harvest impacts as shown
in Exhibit 4. The total first decade harvest increase due to
an intensive management program was allocated to the several
practices in proportion to the effects of those practices on
per acre yields in a fully regulated forest over a rotation.
The genetic planting program produces the largest impact
during the first decade. An additional 28.4 million board feet
in first decade annual harvest can be attributed to planting
1,520 acres with genetically improved stock. The combined pre-
commercial and commercial thinnings provide the next best invest-
ment opportunity.
Mason Bftucc a Giaaho Inc
Mr. Robert E. Ragon
August 20, 1982
Page 9
The selection of a plan alternative should consider the
DO~22 effects of possible short falls in funding of the planned manage-
ment practices. We have estimated that a reduction of only about
$3 million in intensive funding after such a plan v.
would reduce the harvest under the preferred alternative to below
the current harvest level of 201 million B.F. However, under
Alternative 2 such a reduction in funding would reduce the har-
vest to about 224 million board feet or about the recent past
level. We conclude from this that Alternative 2 is a much
better alternative for implementation because it contains a
base that is large enough to provide better assurance c
timber supplies. To illustrate this we calculated the ■
land area (under natural growth) that would be needed to replace
the allowable harvest lost due to lack of funds for the inten-
sive management program. (See bottom of Exhibit 4.
estimate that over 176,000 acres of unmanaged forest land wc
be needed to replace the 89 million board feet harvest volume
attributable to intensive managemei
Cost Efficiencies for Individual Intensive Practices
Reforestation and replanting costs on the Roseburg District
are a substantial part of the forest management bu. have
noted above. Our examination reveals that these arc also high
on a per acre basis. Therefore, in terms of improving efficiency,
this cost bears closer examination as a possible target for cost
reduction efforts. We have reviewed planting costs for other
agencies and industry and show the results in Exhibit 6. As a
128
68 23
Mr. Robert E. Ragon
August 20, 1982
Page 10
concern ovei
cost reported in the DEIS for the Roscburg District. Foi
two local national fori State of Oregon and forest industry,
planting costs arc significantly lower than the Roscburg Di
The costs reported for chemica 1 release, precommercial thinning
and fertilization on the Roseburg District seem to be more in
line with those of the other land managers. It should be noted
that reforestation expenditures are made in the first few years
of a rotation and therefore significantly affect the soil
expectation values (SEV) shown in the DEIS. We will have more
to say about this lat.
Our concern here is with the need for an effort to reduce
BLM regeneration costs. It is our recommendation that BLM should
include in their plan provision for specific regeneration cost
reduction efforts during the plan decade. Such reductions would
better assure that management funding from 25 percent of receipts
would be adequate in the future-.
Effects and Costs of Extended Rotations
The extended rotations used to provide for other resource
values have a substantial impact on the allowable harvest of the
District. We believe that BLM has not properly informed the
DEIS public reviewers of the highly significant impact of reserving
areas for management under extended rotations of 250 years without
intensive management. Our calculations indicate that this manage-
ment will use five times as much area to produce a given volume
of annual harvest as the area needed under intensive management .
Mason Bruce ft G.waro Inc
Mr. i i -igon
August 20, 1982
In I
needed to produce one million board ft_-el of al
harvest under intensive managemei
of 250 years. The capitalized annual costs of management only
{without capital cost of the land and growing stock i
$633,900 for the 1,018 acres of intensively managed lands and
$450,700 for the 5,020 acres of extended rotation lands,
indicates that the management cost of producing one million board
feet under an extended rotation is lowest. However, one must
evaluate the cost of the necessary extr a area of 4,002 act
the regulated growing stock on that area. The average acre under
a regulated condition with a 250 year rotation would contain a
stand 125 years of age. In our opinion such lands would
a cost value, if obtained in the Roseburg area, of at least
$5,000 per acre. Thus, we sec that an extra capital cost of
$20,000,000 for the extra 4,002 acres would be required in
addition to the capitalized management cost of $450,700 in order
to produce one million board feet annually. This illustrates
the exorbitant cost of timber output from extended rotations.
All possible effort should be made by BLM to use other means
or much shorter extended rotations to provide the other resource
values.
Significance and Reliability of Soil
Expectation Values in Choosing an Alternative
The soil expectation values (SEV) contained in the DEIS
are the result of a new analysis on the part of the BLM. We
68 24
Mr. Robert E. Ragon
August 20, 1982
Page 12
agree that detailed economic analysis is needed to help determine
the most efficient timber producing regime . However , we are
concerned about the methods used and the impl ications of the
SEV calculations.
First of all, we have not observed the use of economic
efficiency as a guide to planning by the BLM in past years . In
fact, many of its management policies such as even flow of har-
vest volume and the goal of regeneration within a 5 year period
fail to measure up under any economic efficiency criteria . Also
we note that the most efficient combination of management techniques
shown in the DEIS are under a 65 year rotation for a managed
stand, yet this was not selected.
It seems obvious to us that SEV's were not used by BLM in
developing the most efficient management prescription . While
we believe these should have been used as guides, we are con-
cerned that the BLM calculations over state costs and are not
entirely reliable. Also, the presentation of many negative values
is misleading.
A major factor in determining the level of the BLM values
is the high regeneration costs in the first years of a rotation.
This causes most of the low or negative indicated values. In
western Oregon millions of acres are being managed on a sustained
yield basis which implies that other land owners/managers are
more cost efficient, or have different outlooks for future revenues,
or require less return on forestry investments .
6825
Mr. Robert E. Ragon
August 20, 1982
Page 1 3
Our examination indicates the treatment of administrative
costs by BLM in their SEV calculations was incorrect. Apparently,
these have been handled this way because of the accounting or
budgetary procedures used within the agency. These tend to be
the same regardless of the alternative and thus they could have
been excluded since the SEV's were only for comparative purposes.
We are also concerned that a portion of the administrative
costs are such items as planning or wildlife management. These
produce other multiple resource values which are generally not
to be included in the SEV calculations used to evaluate timber
production efficiency.
The SEV calculations should use a discount rate that reflects
real rate of return appropriate for the federal government. The
U. S. Forest Service recently conducted a detailed study about
appropriate discount rates and came to the conclusion that 4
percent was an acceptable real rate of return for government use
in planning. We concur.
We believe that the BLM assumptions about future price
increases for forest products are realistic. The BLM may have
used an initial price level that was too high. However, a lower
initial price per MBF would not likely change the SEV's cal-
culated because the revenues are in the distant future.
Regarding SEV's our recommendation would be that the BLM
reexamine their purpose and usefulness in preparing the plan
and to limit their presentation in the EIS to only a few critical
values as they relate to the final selection of management regimes.
Mason Bmuct ft Gi»*wo Iwc
129
Mr. Robert E. Ragon
August 20, 1982
Page 14
These values should be determined with a 4
which gives greater weight to more distant values and costs, thus
reflecting government's concern for future generations.
We would be pleased to discuss any of our findings or
recommendations with you or members of the Roseburg District
staff in del i
Sincere ly ,
Carl A. Newport
David R. Cox /
CAN:DRC: jlf
Attachments
EXHIBIT 1
ESTIMATED SALES, HARVEST RATES AND PROJECTED REV
ON ROSEBURG DISTRICT, BI,M
IN FY 1984, 1985 AND 1986
FY Year
1981
1982 (est.)
1983 (est.)
1984 (est.)
1984
1985
1986
Estimated
Sales
MBF
182,900
185,000
200,000
246,000
Harvest Harvest
Level Value
MBF $/MBF
150,800 $322
Aver
Sales Value
5/MBF
$259.81
150.00
180.00
216.00
Optimistic Value Level
185,000 260
190,000 150
200,000 180
O S, C 25%
Funding From
Estimated Ha rvest
i on $
12.1
12.025
7.125
9.000
Pessimistic Value Level
1984
1985
1986
185,000 200
190,000 130
200,000 150
9.250
6.175
7.500
EXHIBIT 2
COMPARISON OF FIRST DECADE
ESTIMATED FOREST MANAGEMENT COSTS
FOR ALTERNATIVES 2, 4 & 5
ROSEBURG DISTRICT - BLM
.1/
EXHIBIT 3
NET PRESENT VALUE OF FUTURE REVENUES AND COSTS-
FOR PLAN ALTERNATIVES 2, 4 AND 2 (WITHOUT INTENSIVE MANAGEMENT)
DURING THE FIRST DECADE OF EACH PL
Present Value Present Value
Alternative
Total Decade Costs-
Total Planting and
Replanting Costs
Planting and Replanting
Cost as a Percent of
Total Costs
$75,218,600 $70,543,400 $60,480,200
33,820,800 31,640,600 23,883,800
45% 45% 39%
Sale Preparation and Admin. 33,689,400 31,477,300 35,299,200
Sale Preparation and Admin.
as a Percent of Total Costs 45%
45%
Total Cost per Thousand
Board Feet Produced
$28.17 $28.33
581
$30.10
1st Decade
1st Decade
Be
nef it/Cost
Alternative
Revenues
Costs
Ratio
M$
M$
4 (BLM preferred)
$491,185
$57,981
8.4:1
2
526,101
61,824
8.5:1
2 w/o intensive mgmt .
350,576
55,162
6.3:1
1/
Revenue and costs discounted at 4 percent from the midpoint
of the decade. Costs (those shown in DEIS on page 121) were
increased at 0.42% and revenues at 1.65% real rates to the
midpoint of the decade.
- Includes costs shown in BLM, Roseburg DEIS on page 121. Costs
are not discounted.
130
COST NATIVE 2
ROSEBURG DISTRICT - BLM
IN OP AREA
NEEDED TO PRODI 1
ANNUAL HARVEST UNDER INTENSIVE AND EX
ROSEBURG DISTRICT - BLM
visive
: ml Ln ai t ei rial Lve 2
Value of Increased Annual
I During Firs! Decade due to
Value of the Annual Costs
t Practices
During First Dot.
Ratio of 1 1
il ed ai lowable Cut El
g First Decade For:
89,280 MBF
5175,525,000
$6,662,000
Intensive
I ice
Extra Acres to Extra Annual
Annual be Treated Harvest per Cost per Acre
Harvest During Decade Acre Treated Treated
Planting 28.1 MMBF
i on 19.6 MMBF
CT 37.5 MMBF
1,520
57,984
42,240
18.490 MBF
0.338 MBF
0.888 MBF
10
72
90
Acres Needed to Provide One
on Board Feet (B.F.) of
Sustained Yield Harve
Acres Harvested Each Year to
Provide One Million B.F.
Total Capitalized Cost of
Management Expenditures to
Produce One Million B.F.
Indefinitely (4% Rate)
Additional Acres Needed to
Produce One Million Board
Feet Under Extended Rotation
Estimated Cost of Additional
Land and Growing Stock Needed
Under Extended Rotation at
$5,000 per acre.
ment Ro-
Regime
1,018 ^c. 5,020 ac.
12.89 ac. 20.08 ac .
$633,900
4,002 ac.
$20,000,000
85, 140 MBF
Additional Acres of Naturally
Grown Forest Land Needed to
Replace and Sustain the Same
Amount of Annual Harvest (85,140 MBF)
as is Obtained by Intensive Management
176,400 acres
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Response to comments in Letter 68.
68-1 See response to comment 4-1.
68-2 The 70,000 acres of old growth remaining under Alternative 7 after
ten decades of management is the result, for the most part, of a
large acreage withdrawal because of reforestation problems. The lands
would occur as small tracts not properly distributed to provide
habitat for the identified spotted owls.
On the other hand, contained within the 68,100 acres of old growth
remaining under Alternative 6 are acres specifically earmarked and
arranged around the identified owls so as to meet their habitat
needs.
68-3 See response to comment 11-8.
68-4 The Oregon Endangered Species Task force management recommendations
and the proposed revision of the Oregon Interagency Spotted Owl
Management Plan provided a basis for EIS analysis, not a specific
proposal for implementation.
68-5 The DEIS was in error. The text has been revised in the FEIS, Chapter
3, Vegetation Conclusions section.
131
68-6 The Glossary definition has been corrected.
68-7 The methodology utilized to determine elk population response to
varying habitat conditions in the Tyee area provided for the
classification of forest stands in excess of 120 years of age as
survival cover. Additionally, stands 45-120 years of age were
assumed to provide summer and winter thermal cover needs. Refer to
DEIS, Chapter 2, Affected Environment, page 45.
68-8 Forest stands 50-120 years of age meet thermal cover needs. Stands
120 years of age and older supply both the food resources and thermal
qualities viewed as important for survival during severe winter
weather periods. The age class spread represents a range of quality
in relation to cover, with the older stand providing better quality
survival cover and being capable of better serving the overall needs
of the animals.
68-9 As stated in the EIS, Chapter 3, Table 3-11, the elk populations are
predicted to decline 20 percent below present levels after five
decades in response to the changes in habitat (cover- forage) brought
about by intensive forest management practices on the habitat they
occupy. Elk would continue to exist. Simply stated, the habitat
quality which exists today is thought to be capable of supporting a
larger population of elk than that which will be a product of five
more decades of intensive forest management.
68-10 The 18 pairs of spotted owls projected to remain in Alternatives 3
and 4 represent a 67 percent decline from existing conditions. This
decline in owl pairs comes as a result of reducing
the old growth base by appro*
relationship, it can be stated thai the ow]
indicator of chan-j
68-11 The text has been revised in the PEIS, Chapter "i, Impai
Transportation System in Terrestrial Vert ' .on.
68-12 The text has been revised in the FEIS, Chapl ts on Animals,
Other Timber Management Treatments section, del*
statement on slash burning.
68-13 Western Oregon biologists have noted slash from pre-comm
thinning lasting 1-2 decades. Approximately 30,000-40,000 acres would
be treated in the first decade, representing about 10 percent of the
SYU acreage and a significant loss of habitat.
68-14 It may be that shelterwood and seed tree harvest provide adeq
forage; however, commercial thinning as practiced in the Ro.v
District creates neither prime forage nor cover. Compared with old
growth habitat interspersed with clearcuts, quality of thinned areas
as elk habitat is considerably less.
68-15 The text has been revised in the FEIS, Chapter 3, Impacts on Animals,
Fish Conclusions section. Temperature has been removed from the
discussion. See response to comment 16-18 for discussion on 9
68-16 The text has been revised in the FEIS, Chapter 3, Impacts on Animals,
Terrestrial Vertebrates, Timber Harvest section.
68-17 See text revision, FEIS, Appendix 3, Table B-2.
68-18 See response to common issue 5.
68-19 As noted on page 114 of the DEIS, an analysis of the economic
efficiency of the forest management practices in the Original
Proposed Action was requested by members of the public during the EIS
scoping process. Soil expectation value was the method of evaluation
requested. Soil expectation value is not a variable listed in either
the original district planning criteria (Appendix C) or the O&C
Forest Resources Policy (Appendix A) to be used in developing plans
for BUA administered forest lands in western Oregon.
68-20 Table B-2 has been revised to increase the number of baselines for
forecasting revenue; however, note that the numbers reported in
Tables 3-1 and B-2 of the DEIS are decadal averages spread evenly
across the period for the purpose of obtaining a discounted
benefit-cost ratio of the timber management program in the proposed
action. No attempt was made to speculate on cyclical ups or downs.
The 1984 to 1986 harvest level reported could be a significant
understatement of actual harvest if the economy is in an upturn and
the more than 616 MM bd. ft. on the district now sold but uncut were
also being harvested. In the case of increased actual harvest, the
number of acres being planted would also be greater than that planned
for in Table 1-2 of the DEIS. Also, see response to comment 15-2.
68-21 Neither the district's planning criteria (Appendix C) nor the O&C
Forest Resources Policy (Appendix A) suggest that a choice among
alternatives will be based on econaru
feasibility was a factor in the selection of intensive management
practices for all alternatives.
68-22 See response to carutDn issue 2.
68-23 See response to common issue 4.
68-24 See response to comment 68-19.
68-25 Table B-l includes interdisciplinary support arid review as a
the district forest management program. The costs of inter-
disciplinary support and review are in Table B-6
DEIS. The baseline yields, costs and revenues of Table B-6 in
DEIS are the determinates of the analysis of soil expectation value.
69
132
ASSOCIATION OF O&C COUNTIES
COWM 0*11 KHMOC* Nil
■INTO* COUNTY COUMTNOVU
CORVA1LI9 OftfOON »'»»
COUU UN '
KM." cowwrv c
0*1 LA* ORIOONtflM
f^f
August 19, 1982
PHOHI kmtmm
■ARROWS COUNUL
B1 I * ISVi ftVtMJl
Mr. Junes Hart, Disc. Mgr.
Bureau of Land Management
777 NW Garden Valley Bvld.
Roseburg, OR 97470
Dear Jim,
On behalf of the Association of O&C Counties, the following response to the
Roseburg District Bureau of Land Management Timber Management Draft Environmental
Statement is here-wlth submitted.
In the past, responses to BLM Draft Statements were intended and limited to
their scope and adequacy. Advocacy of a particular plan was the subject of the
response to the Final EIS . We understand that the process has now been changed
where-by the FEIS will, in effect, become a Tentative Decision Document. Thus
this response will not only critique the DEIS but it will also set forth our druthers.
The DEIS appears to be adequate in scope and is sufficient in detail on most,
but not all, Issues. Our concerns are listed and discussed in the following para-
graphs .
COMPARATIVE COSTS
Nowhere in the DEIS is there a table showing the budgetary requirements of
each Alternative. The lack of such data leaves the responcUr and the decision
maker in the dark. Each Alternative is developed on the premise that there will
be full funding. Past and present trends of Congress indicate that unlimited
funds will probably not be available. Thus after a plan is selected and implemented,
the annuaL timber sale will still have to be tailored to fit the available funds.
We remind that the days of easy money due to the use of a generous 25% plow-
back fund appear to be over. 25% of projected receipts during the next decade
will not be sufficient to meet the needs of Alt. 5 (the Ejdsting), much less, monies
needed to carry out the higher level of intensive management called for in Alt. 4,
(the Proposed Action).
We are not faulting the District for proposing a higher level of intensive
management, we commend you. But the reality of full funding is Is doubtful, accord-
ingly, the chosen plan must be responsive and flexible to the mode of each years
Congressional monetary priority. Because of their higher timberland base. Alternatives
I and 2 will be more adaptable i:o funding deficiencies than the other Alternatives,
including the Proposed Action.
Mr. James Hart
Auguit 19, 1982
We trust that the Pinal EIS will contain the projected cotti of each rltar-
native .
DEPARTURE FKOM NON-DECLININC EVEN-FLOW
The DEIS leads one to believe that any departure that takes the allowable
harvest below the Long Run Sustained Yield for any period of time is illegal.
This Is not so - It Is simply Bureau policy. Historically the private timber lands
of Douglas County have provided the lion's share of raw wood for local manufacturing.
Only in very recent decades have the Federal tlaberlanda made any sizable contrib-
ution to the needed supply. The result of this imbalance Is that private stands
of harvestable timber are In short supply and their new stands of regrowth
are a few decades from maturity.
Table C-l shows that over one half of the BLM acreage In the .District is above
rotation age. This over-abundance of mature timber compared to a short supply of
growing stock is almost the exact opposite of the situation existing on the county's
industrial private forest lands. Private growers are short on mature timber and
long on reprod. It appears that each (private and federal) have what the other
needs for a balanced age-class distribution. If not now, surely this possibility
of departure should be explored prior to the next decadal planning exercise.
CONSISTENCY WITH THE O&C ACT ANT) OTHER LAI'D USE PUNS
The O&C Act specifically stresses the stability of local communities as a major
purpose. The Federal Land policy and Management Act states that the land use plans
of the .Secretary "shall be consistent with State and local plans Co the maximum
extent that he finds consistent with Federal law and the purposes of the Act".
The DEIS Indicates that the Proposed Action is not consistant with the Forestry
Plan for Oregon and we submit that the larger acreages of land set aside for
unprotected wildlife species is not in compliance with FLPMA or the O&C Act.
FERTILIZATION
We note that the PA provides for about 56,000 acres of chinned stands to be
fertilized. This is a commendable start. However, we believe that among the
_ 100,000+ acres of stands under Che 30 year class shown on Table C-l, chere is also
Qy~^ an opportunicy for a fertilizer program on some unthinned stands. We recommend
that these acres be surveyed to determine if such a possibility exists. If the
survey finds, as we expect, that some unthinned stands can be benefited, the plan
should allow for it's immediate implementation. Lost production is lost forever.
VISUAL MANAGEMENT
Because of the mixed ownership pattern, it is doubtful that any BLM visual
I control will be of any meaningful value. We believe that chat the BLM's visual
management program should be restricted CO only those areas so designated as scenic
routes by the Federal, State or Local governments.
In addicion where che BLM's ownership is incer-mixed with unrescricced privace
lands, we submic chat the 250 ya minimum harvesc age Is much too high. In our
detailed analysis of the Coos District plan, we concluded that a 120 MHA was
sufficient. Under the Area Control Harvest concept as proposed, only 1.2% of the
land area would be disturbed annually or 12% during the decade.
Mr. James Hart
August 19, 1982
MANAGEMENT CRITERIA AND CRITERIA APPLICATION
July 11, 1982
This Association put forth considerable effort and resources in responding
to the Co^s-Curry EIS . You have previously been provided with a copy of chac
report. We are please to note that the Association' s views as set forth in that
document mesh well with the new criteria adopted by the National Director. If
interpreted and followed as we expect It to be, a high level of output can be expected
without undue environmental degradation.
SUMMARY
(1) The highest possible level of timber production should be the goal
consistent with applicable laws and regulations. (2) Amenities not required by law
should be carefully blended within the the timberland base in e manner thaC does
not unduly interfere with timber production. (3) Budget requirements of each Alt-
ernative must be known before a decision can be made. (4) All incensive managemenc
practices with a positive B/C should be Included regardless of which Alternative
is selected.
CONCLUSION
In consideration of the above and the information within the DEIS, we believe
that the output level of timber can be higher than that of the Proposed Action.
Without the benefit of computer data and professional assistance, Alternative 2,
combined with the adjustments required by the new criteria, appears to be our
preference. We also note chat Alt. 2 reaches che regulated position in less time
and that the period where some 50 year old stands will be harvested is shorter
by one decade.
Finally, we commend you and your able staff for a job well done. The DEIS
reflects sincerity, devotion and inventiveness. We know that you will take our
comments In the constructive light that is intended.
Respectfully submitted
Ray E. Doerner, Exec. Dir.
Response to comments in Letter 69.
69-1 Neither the district's planning criteria (Appendix C) nor the O&C
Forest Resources Policy (Appendix A) suggest that choice among
alternatives will be based on funding requirements. Common issue 2
projects the district's timber sale offerings if funding were
insufficient to meet the district's commitments to intensive
management in Alternative 9, the Preferred Alternative.
69-2 Generally, fertilizing unthinned stands more than 10 years prior to a
commercial thinning entry or final harvest does not yield an economic
return. Fertilization plans in the Preferred Alternative (Alt. 9)
include unthinned stands which exhibit spacing characteristics of
thinned stands.
69-3 The Preferred Alternative includes special visual considerations for
BLM recreation areas and State of Oregon designated scenic areas.
Refer to DEIS, Chapter 3, page 82. Also, see response to comments
58-2 and 58-3.
71
133
Western Forest Industries Association
1S0O S W. TAYLOR STREET • PORTLAND. ORECON 97205
TE LEPHON E
SO 3 - 224- 5455
August 18, 1982
Mr. James E. Hart, District Manager
Roseburg District Office
Bureau of Land Management
777 N.W. Garden Valley Blvd.
Roseburg, Oregon 9 74 70
Re: Roseburg Timber Management Draft Environmental Impact Statement
Dear Mr. Hart:
Western Forest Industries Association (WFIA) appreciates the oppor-
tunity to comment on the Draft Environmental Impact Statement for the
Roseburg District Timber Management Plan and your proposed action. Our
Association is comprised of approximately 100 manufacturers of lumber
and plywood with mills located throughout several western states. These
firms are primarily small, independently-owned businesses that share a
mutual dependence on timber produced on public forest lands for a source
of raw material. Several of our members are major purchasers of BLM
timber in western Oregon, including the Roseburg District. Consequently,
we have been deeply involved in reviewing the timber management proposals
being prepared by several BLM districts. The future viability of our
members, and the stability of the communities that are dependent on their
operations, will be determined by the long-term productivity of public
forest lands.
In quite simple terms, we believe the future availability of timber
from public lands will be determined by the amount of commercial forest
71-1
Mr. James E. Hart
August 18, 1982
Page Two
land preserved for timber production purposes. Our goal in participating
in your planning process is to maintain or expand the intensive timber
production base. This goal is shared by the Oregon State Department of
Forestry in its objectives for the Forestry Program for Oregon and by
the House of Representatives of the Oregon State Legislature (see House
Memorial ffl, enclosed). Unfortunately, all of the BLM proposals made
to date are inconsistent with this goal. Your proposal is no exception.
While timber production will increase by 48 million board feet per year
under your proposed action, the increase in yield will occur on nearly
44,000 fewer acres. In order to implement the alternative, significant
increases in intensive forest management investments will be required.
As an Association of forest industry concerns, WFIA applauds your leader-
ship in promoting the latest scientific advancements in forestry. How-
ever, we do not support, and in fact oppose, the use of intensive manage-
ment investments as a vehicle to trade away productive forest land for
unsubstantiated non-timber uses. Paramount among our many concerns is
the outlook for revenue to finance the intensive management program you
have proposed. Your cash flow scenario assumes future stumpage prices
in excess of $300/MBF and that timber currently under contract will be
harvested. In light of the less than certain future for funding intensive
management, it would seem prudent to analyze some alternative means of
achieving the same timber production objectives suggested in the proposed
action. We believe the most viable option is to increase the amount of
land allocated to intensive timber production. Such an alternative would
most likely result in a more cost efficient method of achieving your tim-
ber harvest goal. The major deficiencies of the Draft Environmental
Impact Statement that lead us to this conclusion are:
1. No analysis of the opportunity costs of re-
moving productive forest land from the in-
tensive timber production base.
Mr. James E. Hart
August 18, 1982
Page Three
Mr. James E. Hart
August 18, 1982
Page Four
71-2
71-3
2. Faulty analysis of expected revenues.
3. Inadequate cost data for implementing each of
the alternatives.
4. Erroneous cost efficiency analysis.
Each of these concerns will be addressed individually.
OPPORTUNITY COSTS
The proposed action includes several classifications of lands placed
in the Constrained Timber Production Base. Habitat for spotted owls,
old growth blocks of various sizes, osprey and heron habitat, riparian
zones and visual management areas totaling 52,047 acres will be placed
in the constrained base and managed under area control. It is imperative
that the opportunity foregone in terms of timber production, income to
the Federal Treasury and the counties, and the benefits to dependent
communities be assessed for each of these resource allocations. The
tradeoffs involved in removing productive land for each of these non-
timber uses can be best assessed by disclosing the opportunities fore-
gone in this manner. The public will be in a better position to under-
stand the relative costs and benefits of these resource allocations.
REVENUES
Table B-2 on page 116 of the Draft EIS displays an erroneous repre-
sentation of expected revenues. For example, revenues expected in 1984
are calculated by multiplying the price of stumpage ($302/MBF) by the
proposed action harvest level of 249 million board feet. There are two
major flaws in this prediction. First, timber sales harvested in 1984
will be those sold in 1981 and have very different stumpage values than
those displayed in Table B-2. Second, the volume harvested in 1984 will
71-3
71-4
71-5
more nearly reflect the sale program in effect in 1981, i.e. 201 million
board feet. Likewise, volume harvested in 1985 will be from sales sold
in 1982, etc. Therefore, the expected revenues displayed in Table B-2
are overstated for 1984, 1985 and 1986. Furthermore, the stumpage rates
forecasted for the planning period may well be optimistic. Some documenta-
tion should be provided in the EIS.
COST DATA BY ALTERNATIVE
In order to perform an acceptable economic analysis of each alterna-
tive, the cost of implementing each alternative is necessary. Table B-l
displays the forest management costs for the proposed action but does not
include total costs or itemized district and State overhead costs. These
cost figures should be displayed for each alternative, along with expected
revenues for each alternative, and discounted back to present net value.
Data displayed in this manner will facilitate a more accurate assessment
of the relative efficiency of each alternative.
SOIL EXPECTATION VALUES
Your use of soil expectation values in assessing the economic effi-
ciency of management regimes is extremely misleading. Bare land economics
may be useful in determining the relative efficiency of alternatives, but
the negative values displayed in Tables B-3 through B-4 imply that the
I management practices are not cost effective. Why you chose this method
of analyzing management opportunities is not clear. The fact is, the
Roseburg District has a large volume of standing inventory that is ex-
tremely valuable. We believe it is inappropriate to ignore this value in
calculating the costs of producing the next rotation. Specifically, re-
forestation costs should be viewed as a cost against harvesting the exist-
ing stand, not in establishing a future stand. Existing laws and regula-
tions require that reforestation be assured prior to making a decision
134
Mr. Jan
August 18, 1982
Page E i
Mr. James B. Mi r t
August 18, 1982
Page Six
to h.ir to charge reforestation
and associated costs again Lng stand rather than the future
stand. The existing stand could not be cut without a commitment to ro-
tation. An analysis of the man ... > ! izlng this more
traditional approach will i more accurate assessment
The Final Environmental Impact Statement should include Information
to satisfy the shortcomings described above. We believe the additional
analysis will demonstrate that the proposed action is a very risky alter-
native relative to funding, will result in tremendous opportunity costs
in terms of intensive timber base reductions, and may we] cost
efficient than some alternative land base/Intensive management mix.
RECOMMENDATIONS
We ask that an alternative with a land use allocation similar to
Alternative #2 be given consideration as the proposed action. Such an
alternative would strike a compromise between current land uses and those
suggested in the current proposed action. Of greatest significance, an
intensive timber production base of approximately 300,000 acres would not
be as sensitive to budget short-falls as the current proposal. In case
of funding shortages, subsequent reductions in timber harvest would not
My as significant. In addition, the benefit/cost relationship
would be more favorable since it would require a smaller investment in
intensive management to yield the same, if not higher, harvest level.
Our recommended alternative would also be consistent with the
Director's July 15, 1982, Criteria for Application of & C Forest Policy.
The current proposed action is not. Specifically, compliance with
Criteria "5 would be better accommodated by Alternative #2 in regard to
the allocation of commercial foi
native would also maintain future options for preserving old growth tim-
ber stands. At the end of the planning period, over 70,000 acre* of old
growth timber would remain on the district
acres of old growth would remain; more than enough to sustain a
population of spotted owls.
When all the major criteria arc considered; I ncy of local
communities on the timber resource, the goals of I , irtment of
Forestry, House Memorial #1, the Director's Criteria for Application of
& C Forest Policy, the tremendous cost of the proposed action, the un-
certain outlook for funding intensive management practices, the cost/
benefit relationship of the proposed program, and the over abundance of
old growth timber, Alternative 02 Is the most prudent and logical choice
for final adoption.
Very truly yours,
WESTERN FOREST INDUSTRIES ASSOCIATION
, 1H
Mr. William Leavell
Mr. Robert Burford
Jj£( Gelslnger /J
ORECONLECISI VTIV
House Memorial 1
c ichucm ol Represents
The following lurtunury is ™.i pn .
!■■, ti,,- I egislative Assembly, li
ininduont.
Urges I niled Slates Bureau
and Ho
I.. ihu Honorable
assembled
Wc, youi memorialists, tra House ol Represents
assembled most respectful!) request il
Management kind use planning in Oregon and specifically
Whin-. in umber management proposal
preparation in all Bureau of Land Managcm
Hoi si Ml. MORI VI i
f Representatives i>( ihe United State* of America,
..l the State of Oregon, in legislative session
, to intervene in the Bureau of Land
in < 'oos B.iv district because
being developed in the Coos B.iy district and in plans under
districts in western Oregon; and
Whereas the limbei manag. n ! ' - ,nd Management's Coos Bay d.smci
k vul bj Id million board feci, eliminate over -00 jobs in the
local area and reduce count) limbei revenues by 2 t million dollars; and
Whereas the pni ihe prop«>sed reduc
reduce the intensive umber production base b]
i> I he Bureau of Land Management's decision to
HI acres lor the exclusive benefit of wildlife and
■.iheiK
and
-natives have been developed <
icd yield ■ •
ol Land Managcmenl thai would allow ,
v jobs in one of the most depressed areas
Whereas the revesting Act of Or. Bay Wagon Road Grant l^nds (43
: • lal that governs management ol mosi Burv; md Managcmenl lands in western Oregon specifics
I " n,K ««M»reo(
dependent communities, .md
Whereas the Oregon economy is dependent or, I sting and processing of renewable timber
anil
Whereas other Bureau of Land Management districts in western Oregon are following the precedent set by
[he t oos Bay district by proposing reductions in the Immci production land base for nontimber uses al the
expense of limber supply, employment ai m of dependent communities; now. therefore.
Ik ll Resolved b) the Housf uf Reprwrnlutnes ol the Stall »l i irego"
(1) Wc urge the Congress of Hi United States to reqi
priority to the following goals in i. a king final decisions
Kcemphawc the importance of ^immunity stabilily.
individual planning districts, and make certain evt
1 iii. i Hie Bureau <•( LmJ Managcmenl give highesl
lht i ik» He district and olher western districts
oil and 'a* base within Oregon and its
y possible effori is made lo preserve the intensive
land Kisc lor umber production purposes
lonal shall be transmitted to each mcmhci "i the Oregon Congressional Delegation
to e.iJi ol Hs Oregon district offices for inclusion ii
manage
(2) A copy of this
lo (he Director of the Bureau of 1 .md Management
the hearings on each district land use plan
ft;
ft
74
Response to comments in Letter 71.
71-1 See response to common issue 2.
71-2 See response to common issue 4.
United States Department of the Interior
MSII AND WII IH 1H SERVIC'l
Portland I
Reference: ES V/l N.
Portland,
135
71-3 See response to comment 68-20.
71-4 Table B-l in the FEIS includes cost data for Alternatives 4 and 9.
Also, see response to comment 68-21.
71-5 See response to comment 68-19.
74-1|
74-2
74-3
To: Roseburg District Manager, Bureau of Land Management
Roseburg, Oregon
From; Field Supervisor, Oivision of
Portland, Oregon
Subject: Review of the Roseburg Timber Management Graft Enviroi
Statement, Douglas County, On
We have reviewed the subject draft environmental statement on I
Timber Management proposal and provide the following comments:
General Comments
Based on the information submitted, the proposed management plan could \\^h
a significant adverse impact on area fish and wildlife resource',.
document does not discuss impacts associated with the preferred alten
in conjunction with anadromous and resident fish. In addition,
concerning the displacement of wildlife through habitat reduc' i
more detailed in the final document. It is also unclear whether wetland
areas within the management unit will be affected.
It is our belief that proper guidelines and selected mitigative me a- i
should be coordinated with any comprehensive plan that you subsequently
adopt. The final document should also consider all practicable means and
measures that could best satisfy identified needs while at the same t
protecting, preserving, and enhancing the quality of the environment,
restoring environmental quality previously lost, and minimizing and
mitigating unavoidable adverse effects. We dre especially concerned about
maintaining a reasonable riparian buffer strip in association with each
stream corridor. Also, bank protection is important in helping to reduce
potential sedimentation and temperature increases.
Specific Comments :
page 5, para 2 . There is no discussion concerning the adverse impacts the
proposed management would have on the fish population in the area.
Additional data should be provided in the final statement.
I page 24-25, table 1-5 . The "summary of impacts" table does not reflect any
impacts on fish or their associated habitat. This catagory should be
included.
-i page 45, para 2 . There is no indication what portion of the existing
74"4l riparian habitat will be altered. This should be addressed in the final
document.
i page 66, para 4 . Discussion of Impacts on riparian habitats and streams by
erosion, landslides, nutrient depletion and road construction should be
expanded and presented in more detail in the final document. Mitigative
_- £tl measures should be implemented to prevent any long term adverse
7*r'"v| environmental impacts.
page 77, para 6 A number of factors which can adversely affect fish are
presented, however, the amount of impact the various alternatives would
have has not been discussed.
pages 77-78 . The harvesting of timber does have an adverse impact on fish
habitat by removing the riparian zone, changing water yields and increasing
the sedimentation. Therefore, these areas should be quantified as much as
possible and included in the final document.
We appreciate having had the opportunity to review this draft. Please feel
free to contact us if you have any questions concerning our comments.
We would also appreciate receiving a copy of the final statement when it
becomes avai lable.
74-7
I^J^dJ^^r^
Russel 1 D. Peterson
Response to comments in Letter 74.
74-1 Wetland areas are included as riparian habitats and thus would be
affected by each alternative as described in the DEIS- Chapter 3,
Impacts on Animals, page 75. It should be noted that the percent of
riparian habitat associated with wetlands is quite small on BLM lands
within the EIS area.
74-2 See response to comment 5-3.
74-3 Impacts are described in Chapter 3 of the EIS. Because the ai
in Chapter 3 concluded the impacts on fish populations would
significant, those impacts are not listed in the summar
Chapter 1.
74-4 Refer to EIS Chapter 3, Vegetation Section and Appendix C f Table C-4,
for discussion on the impacts to riparian areas from each
alternative.
74-5 See response to comments 5-3 and 74-4- as indicated on page 26 of the
DEIS, additional environmental assessment of timber sales will
address riparian habitat, erosion, landslides and road construction.
74-6 See response to comment 5-3.
74-7 See response to comment 74-3.
78
136
^r
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78-2
78-3
78-4
£■****. <£L«^£^, ,
-
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137
Response to comments in Letter 78.
78-4
*#-&£ £>. t^^rU-LO^
78-1 See response to comment 12-1.
78-2 Table B-2 has been revised to increase the number of baselines for
forecasting revenue.
78-3 See response to common issue 5 .
78-4 The existence of "surplus inventory" is closely linked to both actual
and potential harvest, as described in the DEIS, Appendix C, page
127. The lack of surplus inventory for the Roseburg District is
partly due to the high level of intensive management practices
scheduled.
80
"Monte Montgome
President
Auqust 20, 1982
James E. Hart
District Manager
BLM Roseburg District Office
777 NW Garden Valley Blvd.
Roseburg, Or 97470
Dear Mr. Hart:
Associated Oregon Loggers (AOL) is submitting the attached analy-
sis of the Roseburg District draft environmental impact statement
(DEIS) , in response to your request for comments . We enthusiast i-
cally support the District's obvious commitment to increase
timber supply, jobs and county revenues. AOL has maintained its
commitment to long range forest planning, despite the current
economic crisis, and we applaud the District' s efforts to plan
for a future where once again there is a healthy demand for
Oregon's forest products.
Since the State Director has advised the Roseburg District that
the proposed action must be amended to conform with new policy
d irect ion, AOL will withhold its final support of an alternative
until we have the oppor tuni ty to review the new proposed action.
We do believe, however, that Alternative 2 provides a good foun-
dation for the new proposed action .
As was suggested by Bob Alver
comments in the attached anal
DEIS to meet laws and regulat
does not comply with several
tions (Subpart 1601) , related
State goals, wildlife habitat
implementation. AOL also bel
not comply with the & C Act
dations for improving the DEI
impact statement (FEIS) into
tions.
ts, your planning coordinator , our
ysis focus on the adequacy of the
ions. AOL believes that the DEIS
sections of the BLM planning regula-
to process papers, consistency with
, economic and budget analysis, plan
ieves that the proposed action does
AOL makes a number of recommen-
S to brinq the final environmental
compliance with laws and regula-
We look forward to continued involvement in your planning
process.
Sue
Pores
Executive Committee
Dan Pugate
Bob Birkenfeld
F. F. (Monte) Montgomery
Bob Lindsay AFF|RMAT|V£ ACT|0N _ EQUAL OPPORTUNITY EMPLOYER
ASSOCIATED OREGON LOGGERS ANALYSIS
OF THE BLM ROSEBURG DISTRICT
DRAFT ENVIRONMENTAL
IMPACT STATEMENT (DEIS)
The discussion below addresses six areas of the DEIS, which AOL
believes are inadequate to meet BLM laws and planning regula-
tions.
& C ACT
The Solic
concluded
dominant
states th
can best
In the ca
will occu
has analy
each Act
signif ica
itor General's opinion, dated
that the O 6 C Act mandates
use on BLM managed O & C land
at "the Bureau must see how w
be achieved on land not avail
se of those areas of land whe
r, the Bureau may choose one
zed its choice in the context
and is satisfied that the par
ntly encroached upon the over
September 8, 1981,
forest production as the
s. The opinion further
ldlife protection goals
able for timber production.
re direct conflict in use
over the other provided it
of the principle goals of
ticular choice has not
all effect of these goals."
This direction from the Solicitor General implies that the BLM
must prepare a well documented analysis or process paper which:
1. Assesses the location, quality and quantity
of wildlife habitat;
2. Defines adequate protection for wildlife habitat;
3. Distinquishes between & C lands, and public
domain lands;
4. Locates wildlife habitats, for each alternative,
on & C lands not available for timber production;
and,
5. Documents the economic and social consequences of
allocating O s C lands to wildlife habitat, if this
allocation is necessary.
Although, this opinion has been in circulation for over a year
now, and the Roseburg District states that they did an analysis
of how to meet wildlife habitat concerns on non-productive & C
lands, there is non process paper documenting compliance with the
& C Act as Solicitor's opinion. Section 1601.7-1, of the BLM
planning regulations, states that:
138
10-1
"Records pertaininq to the analysis and
conclusions reached by the Ditrict Manager
and staff throuqhout the planning and
environmental analysis process shall be maintained.
...Such records shall be kept filed together
and shall be available on request for public
review. "
*A0L recommends that a proposed action be developed, which
complies with the & C Act and Solicitor's opinion.
*A0L recommends that the final environmental impact statement
(FEIS) include a process paper which documents the allocation of
6 C lands to timber production and wildlife habitat. This
information is of critical public concern, especially with the
new Washington and State office direction on this issue.
FORESTRY PROGRAM FOR OREGON
ntenance of the commercial forest land
e level, is of great concern to AOL. We
all alternaties, except #1 and #5, are
of Forestry objective regarding main-
Section 1601.4 (c) (1), of the BLM
ates that resource management plans will
sible with existing officially adopted
lated policies, plans or programs
The proposed action reduces the land
1.6%). AOL believes that the BLM has not
tion to comply with Section 1601.4 (c)
As we discuss below, mai
(CFL) base at a resonabl
noted in Table 1-7 that
inconsistent with Board
tenance of the CFL base
planning regulations, st
be "as consistent as pos
and approved resource re
of... state agencies
base by 43,779 acres (-1
designed the proposed ac
{1) as required.
*AOL recommends that the FEIS reconsider the size of the commer-
cial forest base in each of its alternatives. The planning
regulations, we believe, call for at least minimal consistency
with the state's land base objective. The BLM must increase the
size of the proposed actions commercial forest land base in order
to comply with 1601.4 (c) (1).
WILDLIFE HABITAT
Over 52,000 acres of the Roseburg District have been allocated to
wildlife habitat or visual management areas. At the end of the
10th decade of the projection, 18 owls are expected using the 300
acre management assumption, while no owls are expected using the
1,000 acre assumption. Futhermore, it is projected that a
"medium" amount of degradation of scenic quality, will occur.
Section 1601.5-4 (a) (9) of the BLM planning regulations, which
describes the analysis of the management situation process, states
that:
"The District manager shall analyze the management
situation to determine the capability of the public
land resources to respond to: Needs, concerns and
opportunities identified through public
partlciation. . . "
This section further states that critical threshold levels should
be considered during the formulation of plan alternate
*AOL recommends that in order to fully comply with these regula-
tions, the BLM should conduct a trade-off analysis of the 55,047
QQ.2 constrained acres to document the effects (in terms of allowable
harvest and budget requirements) of incrementally adding these
acres back into the intensive timber management base. The BLM
I should further provide a listing of spotted owl pairs by decade
for ech alternative. This should include the amount of habitats
under both the 300 acre and 1,000 acre assumption.
ECONOMIC AND BUDGET ANALYSIS
The BLM conducted several economic and budget analyses, on the
proposed action for the Roseburg District, as requested by the public.
Section 1601.5-2 (a), of the BLM planning regulations, defines
the purpose and use of planning criteria.
"Planning criteria shall be used to evaluate
alternatives and to select one alternative to
serve as the proposed resource management plan."
One of the criteria developed for the Roseburg District states
that:
"Each alternative was evaluated according to the
degree to which it would. . .provide for a high level
of contribution to local public revenues from
resources and activities available on public lands."
Since economic and budgetary analysis where conducted, only on
the proposed action and Alternative 3 it is difficult to
understand how the BLM used the above criterion to select the
proposed action.
-3-
J04
*A0L recommends that an economic and budget analysis be conducted
foe each alternative. Only in this way can the "revenue" cri-
teria be properly used to select the proposed action, which will
not only provide a high level of contribution to local and public
revenues, but will also have a budget that is fundable.
PLAN IMPLEMENTATION
The proposed action reduces the commercial forest land base by
43,779 acres (-11.6%) and increases the constrained land base by
38,161 acres (+73.3%). Precommercial thinning acres are
increased 28,429 acres (+230%), fertilization is increased 56,02^
acres (+100%), site preparation is increased 23,723 acres
(+30%), and planting is increased is, 795 acres (+30%). Finally,
the required budget for the forest management and development
would increase from 50.7 to 83.8 million (Table B-7) dollars in
decade 1, a 65% increase.
From these figures, it is apparent that the District has huilt a
very costly proposed action in order to accomodate multiple uses
of the forest resource. In order to increase the allowable cut
level, on a reduced land base, a costly array of intensive manage-
ment practices has been proposed by the BLM. Since the BLM now
obtains its funding for forest management by congressional
appropriation, the huge budget requirement of the proposed action
(a 65% increase from the present budget) may not be able to be
completely funded.
If the Roseburg District does not receive full funding for the
proposed action, then the level of intensive management scheduled
cannot be achieved and the annual allowable harvest level must
be reduced. Certainly the most cost effective way to raise har-
vest levels it to maintain the number of commercial forest land
acres allocated to intensive management. Smaller quantities of
costly intensive management practices could be utilized on a
larger land base to reach the same allowable cut level.
*AOL supports the choice of implementable plans and the main-
tenance of the commercial forest land base at a reasonable level.
The proposed action is not acceptable because of its reduced land
base and high budget requirements, which hinder its ability to be
implemented. Development and approval of unimplementable plans
certainly violates Section 1601.0-2, of the BLM planning regula-
tions, which states that the objective, of Subpart 1601, is to
"improve resource management decisions on public lands..."
-4-
Response to comments in Letter 80.
80-1 BLM planning regulations became effective September 6, 1979. The
December 3, 1979 Federal Register included a display of BLM planning
efforts underway on that date. Roseburg District was shown as a
Category C, district-wide Management Framework Plan revision to which
the new regulations were only partially applicable. Although
regulation 1601.7-1 is applicable to the Management Framework Plan,
through the development of a preferred alternative, it does not apply
to the Timber Management EIS.
The preferred alternative and other alternatives considered have been
presented in a summary brochure prepared in September 1981, which
indicates land use allocations applicable to EIS Alternatives 1, 4, 6
and 8. Refer to DEIS, Appendix C, Tables C-2, C-3, and C-4 for
allocations by alternative. Analysis in the FEIS includes Alternative
9, which is based on the new C*C Forest Resources Policy (Appendix
A).
80-2 See response to common issue 4.
80-3 The entire 43 CFR 1601.5-4 regulation section is not required for any
transition period Management Framework Plan. Also, see response to
comment 11-8.
80-4 See response to comments 68-19, 68-21 and 69-1.
83
139
nORTH WEST TimBER RSSOCMTIOII
13S6 OAK STREET
TELEPHONE 15031
PO BOX 5554
6869603
EUGENE OREGON 9)405
August 20, 1982
Mr. James Hart
District Manager
Bureau of Land Management
777 NW Garden Valley Blvd.
Roseburg, OR 97470
Oear Mr. Hart:
On behalf of North West Timber Association I am pleased to comment on the Draft
EIS for the District's new Timber Management Plan. Our Association consists of
small independently owned lumber and plywood manufacturers in western Oregon
and southwestern Washington, including several firms which purchase timber
directly from the Roseburg District. Our members are almost exclusively
dependent on federal land for their timber supply thus making the decision for
the Roseburg District critical to the survival of the firms and the economic
stability of the communities in which we operate.
We have been deeply involved in the planning activities of all the western
Oregon districts and are pleased that the content of your EIS has recognized
many of the problems that appeared in earlier efforts. Bureau of Land Manage-
ment planning is a complex and difficult task. In all fairness, we compliment
you, as well as the District and State staffs, on the open and professional
manner in which you have conducted the planning effort and attempted to accom-
modate the many publics interested in your planning.
At the outset we believe it is essential that the time frame of the planning
decision and its relationship to current economic conditions be put in perspective.
The new plan will be long term in that it considers effects of continuing the
plan for many decades. However, in reality, it is relatively short term in that
it will have an operational life of approximately one decade after which adjust-
ments will be made in a new plan to reflect changing information and conditions.
We are currently in the worst economic recession the local industry has ever
seen and most- -if not al l--operations in the county are struggling with the very
basis of survival. Clearly this has temporarily affected the demand and value
of stumpage and it may be several years before conditions return to "normal".
We as an Industry are optimistic, however, that a turn around will occur and
that timber supply will return as the major controlling factor in the health
of our Industry and local economy. When this will occur cannot be predicted,
but when the new plan is implemented in 1984 we should be on our way.
Mr. James Hart
83-1
August 20, 1932
The remainder of our comments will fall into three general categories: I) The
Planning Process; II) Adequacy of the EIS; and III) Identification of a
Proposed Action.
I) THE PLANNING PROCESS
Since the outset of the planning process a concern has existed over the fact
that the BLM's procedures did not provide for a change in the "Proposed Action"
(PA) between the Draft and Final EIS. This seems to have changed in recent
months since the Salem District indicated they would consider changing the PA
between the Draft and Final EIS. Furthermore, the July 15, 1982, Criteria for
Application of 8 C Forest Policy from Director Bob Burford directs that the
new criteria be utilized in the Roseburg EIS process.
It is clear, from discussions with the District staff, that how this will be
implemented is still a matter of debate to be addressed in analysis of input
to the draft. One of the purposes of an EIS and its public review is to focus
on a proper decision. Changes from the current PA in the final decision will
be necessitated by the Director's criteria. Therefore, it seems only logical
that the process be facilitated by a change in the alternative identified as
the PA in the Final EIS. This will not, however, require that the PA in the
Final EIS be the implemented decision since the draft decision process remains
intact.
Contrary to State memorandum OR-82-601 , it is our suggestion that the planning
team attempt to identify, from the existing alternatives, the one which best
meets the directive on & C criteria, other laws and decision criteria and
identify it as the PA in the Final EIS. Each alternative should then be
analyzed as to how well it conforms. The EIS will then point out changes that
may be needed in the remaining step of identifying the final decision. There
is no reason that this cannot be most efficiently accomplished with a short
form Final EIS.
II) ADEQUACY OF THE EIS
One of the main purposes of public review of a Draft EIS is to identify areas
where the statement may be inadequate. We feel that additional analysis is
needed in a number of areas.
A) LAND BASE TRADE OFFS . The reduced timber production from the constrained
timber production base represents some opportunity cost in terms of timber
production foregone. While a comparison between alternatives shows the over-all
effect and estimates can be made on an average per area production basis, specific
I effects by land allocations are not isolated. We believe that the harvest
contribution foregone compared to full intensive management for each special
land classification, as identified on page 124, should be shown. A display
similar to what is needed can be found on page B-3 of the Eastside Salem Draft EIS.
B) BUDGET ANALYSIS . The EIS deals not just with environmental effects, but
also with economic impacts. Since the harvest level will vary with the amount
of funding that is available this will have a critical effect on local economics.
Mr. James Hart
August 20, 1982
Mr. James Hart
August 20, 1982
83-2
83-3
On page 64 of the EIS it states, "A basic assumption of the analysis is that
sufficient funding and personnel will be available for implementation of the
final decision." We feel that this is an extremely weak assumption which
deserves attention in the Final EIS. Blind acceptance of this assumption can
lead the reader into a false feeling of security. Our concern is particularly
heightened when one notes that the projected annual costs of intensive management
for the proposed action (page 116) of $8,411 million is an increase of 42 percent
over the current program of $5 - 9 million; and further, that these figures do not
include either District or State Office administrative overhead which runs
several million dollars per year. While the long run projections appear
favorable, we are particularly concerned with the reliability of the assumption
in the first few years of the program. Economically efficient harvest increases
will be especially important as we work our way out of the current economic
conditions. The recent reduction in the annual sale programs at Medford and
other districts due to budget constraints indicates the reality of our concern.
While the BLM cannot be expected to forecast the willingness of Congress to
approve budgets, we do believe that the decision makers and the public should
know the relative cost and risk of various alternatives. Therefore, we request
that the Final EIS display--for each al ternative--the following information:
1) The average annual cost of the intensive management program during the
first decade with the cost isolated as shown for the PA on page 116,
table B-l.
2) The administrative and overhead costs, including an appropriate share
of State Office costs, such that when added to number 1) above, it
will show the total cost of operating the district.
3} The "current situation" values for items 1) and 2) above.
4) An analysis which would show the sensitivity of the alternative to
fluctuations in budget levels. This would basically begin at the
Q3— 4 harvest level proposed for each alternative and display what the
harvest level would be at reduced budgets, in five percent increments,
until the levels reach what you would consider the minimum that could
be expected.
C) THE SPOTTED OWL . When the EIS states that Northern Spotted Owl "...is
dependent on old-growth, closed-canopy forests..." (page 78) it reflects the
attitude that has polarized an important issue. For several years Industry has
been urging the BLM and other federal agencies to seek out more economically
efficient management strategies for providing for the owl. Instead, the agency
has continued to accept without question the opinions of the Spotted Owl
Committee which continues to base its views only on what the owl appears to use
or prefer--not what it needs to survive.
Even though the Director's criteria clearly established the BLM's policy regarding
the owl on & C acres, this has not reduced Industry's concern for the bird.
As was pointed out by the Fish and Wildlife Service in their January 1982,
83-5
Status Review, the species is not Threatened or Endangered. Due to vast acres
of mature and old growth on the District it is clear that opportunity to protect
the owl without reductions in timber harvest levels exists on the Roseburg
District. The Draft EIS fails to recognize this fact, instead it indicates that
the owl may disappear completely in one hundred years and states, "...it is not
possible to predict when various pairs would have their habitat removed."
This dooms-day, hide-your-head-in-the-sand approach must be corrected in the
Final EIS.
During the scoping process on the District, I requested that the BLM analyze
the opportunity to maintain the owl habitats through each of the first several
decades of the planning horizon. This request was not met. However, I believe
it is extremely important for the public to see and understand the results of
such an analysis. We again request that it be included in the Final EIS. The
Final EIS should contain an array which, beginning with current owl populations,
shows for each alternative and each decade the number of 300-acre habitats and
pairs of owls that can be maintained to the end of each decade. This should
be carried through at least the first four decades and should not contain
replacement stands. It should not be necessary to analyze the 1 ,000-acre core
concept since the letter transmitting the proposed revision of the Spotted Owl
Management Plan indicated little confidence in this figure and only asked that
such allocation be maintained for a period of five years. Clearly, during the
first decade of the plan the District population will not drop below viable
population levels even if no attention is given to the owl. While the development
of this array will require many "best estimates" this should not be a serious
concern considering that most of the spotted owl policies today, and many of the
outputs for other resources shown in the EIS, are indeed little more than best
estimates by the various specialists. The basic assumption that must be used
in developing the array is that the BLM would schedule harvest units in a manner
that will maintain the greatest number of habitats for the longest possible time.
The analysis is very important because it will give the public a more realistic
view of the spotted owl issue and will provide some idea as to how much time we
have to complete our research and study.
Another important addition to the EIS should be to discuss and describe the owl
and old-growth research that is planned for the next decade including what will
be done by the BLM and other agencies; and exactly what type of information
will become available.
When the Preferred Land Use Alternative was presented to the public for comment
in September 1981, an important concept was presented and contained in the
statement on page 23:
During the planning period (the next decade) there will be minimal impact
on habitats of the Roseburg District.
IThe discussion then pointed out that it would be four to five decades before
the impacts might become critical. This whole discussion was eliminated from
the Draft EIS. To those of us in the public looking for rational solutions
83-6
140
Mr. James Hart
August 20, 1982
Mr. James Hart
August 20, 1982
83-8
839
83-10
to the problem of wildlife conflicts, the exclusion was unfortunate. It is
a common misconception by the public that some species of wildlife are about
to be wiped out in the District. The BLM must take the responsibility of
demonstrating that the fears are unfounded and that reasonable wildlife manage-
ment policy is part of the Bureau's activities.
D) AREAS OF CRITICAL ENVIRON ME NTAL CONCERN (ACEC's) , The EIS is inadequate
scussion of ACEC's Fal Areas (RNA's). More complete
descriptions of the areas, why they are considered, and the decision criteria
that will be used should be presented. Before any designation is final it should
be demonstrated that such allocations are justified and the planned management
explained. In the case of RNA's it should be shown that the proposed areas are
the best candidates available in the state for the particular ecological unit
being protected.
E) WILD AND SCENIC RIVERS (page 27). The Final EIS should indicate which
rivers in the District have been included in the National Park Service Inventory,
the rating assigned in the Inventory, and how long the inclusion in the Inventory
is expected to restrict management.
F) FORESTRY P LAN FO R OREGON . The analysis of alternatives in terms of
compliance with the goals of the Forestry Plan for Oregon needs to be expanded,
especially since compliance is a criteria identified by the Director. The
analysis should not simply group the alternatives into classes of consistency
as in table 1-7, but should rank each alternative from most consistent to least
consistent. Where possible the analysis should deal with quantified output
values to demonstrate the level of consistency.
Another important indication of the policy of the State of Oregon regarding the
management of the S C lands is House Memorial Number One, which was passed
„. ...a |in the last regular session of the Oregon Legislature. The Final EIS should
Oo'll |present the Memorial and indicate the degree of compliance of each alternative.
G) FACT VERSUS OPIN ION. There are a number of discussions within the EIS
which appear to be oriented at promoting particular viewpoints about the manage-
ment of the BLM lands that are contrary to the mandates of the & C Act. These
discussions utilize "buzz" words and technical jargon that sounds impressive to
the general public, but actually contribute little to the value of the EIS.
Examples are the discussions of old-growth and forest productivity on page 42
and ecosystem management on page 71. The statement that the symbiotic relation-
ships in old-growth stands "...may prove critical to long term timber production.,
is clearly a less than professionally accepted opinion. These discussions
also failed to draw the important distinction between forest productivity in
natural stands and productivity in managed stands.
H) NON-TIMBER BASE OUTPUTS . A major short-coming of the Draft EIS is that it
tends to deal just with that portion of the District which meets the TPCC
1 criteria for intensive management. Non-timber outputs from the withdrawn lands
are extremely important to the public and should be fully discussed and displayed
in the EIS.
I) DEPARTURES . We are pleased that a discussion of departure alternatives
was included in response to our proposal. While the review was incomplete
it did indicate that opportunities to meet social needs may exist beyond the
rigid even-flow concept while still meeting the basic values of sustained yield
management.
Ill) IDENTIFICATION OF A PROPOSED ACTION
As discussed earlier it is desirable, if not required, that the proposed action
be changed in the Final EIS. Since further adjustments will be possible in the
decision process if the analysis indicates they are needed, we can see no reason
for the BLM to attempt to generate any new alternatives. Rather, our review
indicates that Alternative 2 will meet the requirements of the law and the
criteria for management of the western Oregon BLM lands as set out by the
Director. Alternative 2 should be identified as the Proposed Action for evaluation
in the Final EIS.
Let us look at some of the key criteria embodied in the 4 C Act and management
criteria in relationship to the outputs indicated for Alternative 2. The
Director set out the policy in seven specific criteria:
Criteron 1 ) Provide an optimum and non-declining yield of wood products to
enhance the economic stability of local communities and industries while
providing for other forest values as required by law. Optimum is defined as
approaching, meeting, or exceeding the State Forestry Plan for Oregon goals.
Alternative 2 does not fully meet this criterion in that the land base and harvest
levels are less than Alternative 1, which conforms with the Forestry Plan goals.
However, in order to meet the other criteria Alternative 2 would appear reasonably
optimum.
Criteria 2 and 3 ) Limit or exclude timber production to protect "...high
public recreational value..." at outstanding sites and "...protect and maintain
scenic quality in areas of important visual value "
Alternative 2 meets these criteria with the allocation of 8,383 acres to visual
management and 1,185 acres for recreation management. This provides assurance
that key resource areas such as the North Umpqua Corridor are protected.
Criterion 4 ) Maintaining water quality at federal and state standards by
incorporating mitigating measures in forest management.
Alternative 2 clearly will exceed this criteron with, in addition to mitigation,
the assignment of over 18,000 acres to the constrained timber base for riparian
zone management.
Criterion 5) Management of non-timber forest values. The criteron provides
for allocations, after analysis of effects; for the protection of wetlands--
including riparian zones--and providing habitat for Threatened and Endangered
species.
Mr. James Hart
August 20, 1982
Response to ocmments in Letter 83.
Alternative 2 provides for non-timber values. The 38,530 acres of the District
withdrawn from the intensive timber base and the 24,786 acres under constrained
management certainly meet the requirements. Over 6,000 acres are provided to
protect the bald eagle, osprey, and heron habitat.
Criterion 6 ) This criterion deals with additional allocation of commercial
forestland. It prohibits allocations "...unless such action is found necessary
to protect future options for maintenance of serai stage distribution assuring
continued high timber productivity."
Alternative 2 clearly protects future options since over 140,000 acres of mature
and old growth will remain on the District at the end of the planning period;
thus, no such allocations are necessary . It may be desirable to set out some
harvest scheduling constraints for the first decade to assure that a proper
cross-section of desirable units is maintained through the decade, but this
would not require withdrawal from the harvest calculation base.
Criterion 7 ) This criterion urges maximum use of intensive management practices
to the degree feasible and within economic efficiency measures.
The effect of this criterion will be shown from further analysis. The practices
with Alternative 2 meet this criterion as well--if not better--than the other
alternatives.
In conclusion, we believe the next step in the planning process should be to
identify Alternative 2 as the proposed action in the Final EIS. The analysis
of this alternative and application of criteria to all alternatives in the
review will then indicate what changes may be needed in making a final decision.
Sincerely yours,
^'L^i-CvtviA^y /*ra<pijztA4>{
Dennis Hayward
Field Forester
83-1 See response to ccmmon issue 4.
83-2 See response to common issue 2.
83-3 Neither the O&C Forest Resources Policy (Appendix A) nor the
district's original planning criteria (Appendix C) suggest that a
choice among alternatives will be based on comparative costs. Table
B-l in the FEIS has been expanded to show the forest management costs
of Alternatives 4 and 9.
83-4 See response to comment 69-1.
83-5 See response to comment 11-8.
83-6 There is a five-year research and development program designed to
coordinate the research on interrelationships between wildlife and
old growth forest habitat. Participants include the Bm, USFS Pacific
Northwest Forest and Range Experiment Station, USFS Regions 5 and 6.
Robert Burford, National Director, BLM
William Leavell, State Director, BLM
BLM's involvement is fully described in a document titled "BLM Role
in Old Growth Forest/Wildlife Habitat Research, Western Oregon"
(available at the Oregon State Office).
141
BLM will provide financial and technical support to the project as
well as conduct some intensive studies and research. Objectives of
the old growth forest/wildlife habitat research program are as
follows-
1. Identify animal and plant species dependent on, or which find
optimum habitat in, old growth forests.
2. Describe, classify, and inventory old growth forest
ecosystems.
3. Determine biological requirements and ecological relationships
of species found in old growth.
4. Evaluate old growth management alternatives and their economic
impacts.
Research questions related to the northern spotted owl will be
focused on objectives 1 and 3, as noted above.
Details on specific research projects are described in the Action
Plan prepared by the Program leader, USFS Pacific Northwest Forest
and Range Experiment Station, Olympia, WA.
83-7 See response to common issue 1.
83-8 See response to comment 11-3.
83-9 The nationwide rivers inventory (Jan. 1982) includes two rivers
involving BLM lands in the Roseburg District: the North Umpqua River
from the Umpqua National Forest boundary to Rock Creek and the Umpqua
River from the confluence of the North and South Umpquas downstream
to the Roseburg-Coos Bay District boundary. No priority rating is
assigned in the inventory. Interim protection will be given to
inventoried rivers pending resolution of the Wild and Scenic Rivers
Act eligibility issue. BLM efforts to determine Wild and Scenic
Rivers Act eligibility are expected to be delayed until the next
planning cycle.
83-10 Chapter 1, Table 1-7 has been revised in the FEIS. Also, see response
to comments 4-1 and 4-3.
83-11 The Oregon Legislative Assembly, 1981 Regular Session, House Memorial
1, is included as an attachment to Letter 71. Consistency with House
Memorial 1 is believed to be the same as consistency with Forestry
Program for Oregon goals 1 and 2, shown in the EIS, Chapter 1, Table
1-7.
83-12 Non-timber outputs from the withdrawn lands are approximated by the
analysis of Alternative 1.
85
Department of Fish and Wildlife
506 SW MILL STREET. PO BOX 3503, PORTLAND, OREGON 97208
August 20, 1982
OREGON DEPARTMENT OF FISH AND WILDLIFE
Comments on
Bureau of Land Management
Roseburg Timber Management Environmental Impact Statement
August 20, 1982
PNRS 820628-068-4
Mr. James E. Hart
Roseburg District Manager
Bureau of Land Management
777 N.W. Garden Valley Boulevard
Roseburg, Oregon 97470
Dear Mr. Hart:
Attached are the Department of Fish and Wildlife comments
on the Roseburg Timber Management Draft Environmental Impact
Statement.
The Roseburg BLM has the best potential of any other BLM
district in Oregon to provide viable populations of all
wildlife species found on the district. It is unfortunate
that the proposed action does not make that provision. Of
greatest concern is the loss of cavity nesting habitat,
and less protection of northern spotted owls than the
minimum number recommended by both the Oregon Spotted
Owl Management Plan and the Roseburg BLM Advisory Board.
We are also concerned with soil erosion, debris avalanches
and stream sedimentation that will result in degraded fish
habitat when natural production of anadromous fish has
been in increasing jeopardy.
I would like to support your proposed plan but cannot endorse
a land use plan that does not at least maintain viable
populations of all existing species of wildlife. I
urge your proposed plan be altered to provide for those needs.
85-1
85-2
incerel
-k
f r
(^ j/hn R. Donaldson, PhD
"Director
85-3
After staff review of the draft EIS, we would like to see the following items
clarified or addressed in the final EIS. The items are of significant concern
to the Department.
General Comments
Mining -
We are aware that the plan is a timber management plan, but we are also concerned
with the impacts of mining on Roseburg District lands. Mining has had severe
adverse impacts on the fish resources of the area and adequate control must be
exerted if full use of both fish and mineral resources is to be realized. We
trust that the FEIS will address mineral resources, and the measures that the
BLM will take to protect fish resources during mineral exploration and development.
Mitigation of Impacts -
I We mentioned in our input dated February 5, 1981 and June 12, 1981 that the impacts
of other resource development can be mitigated. Expected mitigative techniques
need to be clearly outlined in the Alternatives. Snags, dead and downed
material are wildlife habitats that can be provided during timber harvest
operations. Herbicide applications can have adverse impact on forage production
for big game but the impacts can be mitigated by considering the supply of
forage nearby and applying herbicide on a portion of the treatment area if
forage is in short supply. Road closures can prevent harrassment of big game
where necessary. These are examples of mitigative techniques that can be
provided regardless of the alternative selected.
Maintenance of Viable Populations of Wildlife -
According to the DEIS only Alternative 8, if implemented, will maintain viable
populations of indigenous species. The Department cannot endorse any proposed
land use plan that does not at least maintain all existing populations of wildlife.
Specific Comments
Page 4 - Summary of Environmental Consequences
Please clarify the paragraph describing the environmental consequences on water
resources. That paragraph discusses the impacts of all alternatives except the
perferred alternative. Sediment yields would increase under Alternatives 1,3
and decrease under Alternatives 5 through 8. What is the expected impact of
the preferred alternative on sediment yield? The information supplied in the
EIS suggests sediment yield would increase as a result of implementing the
proposed action.
|42 PNRS 820628-068-4
August 20, 1982
Page 2.
PNRS 820628-068-4
August 20, 1982
Page 3.
Alternative 4 states: "this Alternative is identical to Alternative 3 except...,
and Alternative 3 will increase sediment yield.
Analysis of impacts on water resources does not include fish life or animals.
Under recreation there is brief reference that fishing would be adversely im-
pacted under Alternative 1, 2, 3 and 5. Please quantify expected impacts on
cold water fish.
o5*4 Page 5. The section on animals needs to be expanded to discuss the impacts on
fish. Increases in water temperature in Alternatives 1 and 5 would negatively
impact fish. The impacts, however, of implementing Alternative 4 are not dis-
cussed and need to be clearly listed. The information presented in the EIS
leads us to believe the proposed action would adversely impact fish. Sediment
yield and stream temperature are already limiting fish populations of Oouglas
County. Page 4 of the EIS says "based on the sample five year sale plan, tim-
ber harvest activities planned in four municipal watersheds would increase
water yield and sedimentation."
Page 13 and page 14 discuss land classifications being managed by Roseburg 6LH.
and C lands and Coos Bay Wagon Road Grant lands are to be administered by
the and C Act of 1937 only where the Act conflicts with FLPMA. Public domain
lands, of which 18,000 acres exist unde' Roseburg BLM jurisdiction appear to be
I managed in accordance with the and C Act. What is the legal justification
for managing public domain lands under the and C Act rather than under pro-
visions of the Federal Land Policy and Management Act of 1976?
Page 24 - Summary of Impacts
The environmental component category soils indicate that 3,072 acres per decade
I of Roseburg BLM will suffer loss of productivity. Please explain how produc-
tivity on 5 square miles per decade can be lost and still meet the intent of
Clean Water Act, Sikes Act, FLPMA, NEPA and Executive Order 11990.
I The summary of impacts lists expected changes in Roosevelt Elk and northern
spotted owl populations. The chart should also indicate the changes in snag
dependent wildlife and fish populations.
Page 44 - Terrestrial Animals
We agree with the statement "of special concern are snags. Snags provide opti-
mum habitat for 33 species and are used, to some extent, by 47 other species of
birds and mammals." "Recent snag surveys by district personnel revealed an av-
erage of 0.1 snags per acre in coniferous forests less than 15 years of age
under BLM administration." The discussion continues indicating the snags are
essential to cavity nesting birds and those birds feed on insects and play an
important part in the control of forest insect pests. We believe that the
maintenance of snags is important and that the Bureau should take greater meas-
ures to provide two snags per acre on clearcut lands instead of 0.1 that are
presently existing.
Page 45 - Riparian Habitat
Riparian habitat on third order and largo
forest land base, some of which has been altered by pa'.'
I practices and is in less than optimum condition. What would
allowable harvest by protecting all riparian habitat on third ordi
instead of harvesting half the timber volume?
Page 66, Table 3-2 indicates the soil productivity win
miles of land on the Roseburg District due to road action
and landsllding from fragile soils. More damage to soil will result from
graveling and nutrient depletion but no data is available to indicr
of damage. On page 67 the discussion of water qua
i ;e by 23 times the natural rote on BLM
to NEPA, an environmental impact statement sho.r
(reduce long-term adverse environmental impacts. What impacts on fish and wild-
life resources will result from the loss of productivity of 12 square miles of
BLM land and the increased suspended sediment yield from sluiceouts and head-
wall fdi lures?
Page 73 - Environmental Consequences, Timber Harvest
The second paragraph of this section briefly Aev oposed modified area
control management and the location of habitat diversity features in a corridor
.-[concept. The final EIS needs to show the location and the wi nidified
85'10l.irpa control corridors. It is our understanding from a meeting we had w
Bureau in 1981 that in many places, particularly the southern portion ol
Roseburg District, that the corridors appeared to avoid productive BLM Lands
and, instead, were routed through private lands over which the BLM has no con-
OC ^^l tro1 - The Final Environmental Impact Statement should predict the effectiveness
O»3'11lof these corridors and how they tie in to corridors proposed by other BLM districts.
Page 73 - Timber Harvest, Third Paragraph, First Sentence:
Late in the third paragraph, the statement made: "the loss in useable old-
I growth habitat is greater than it appears in appendix F,..." In the final
impact statement, please indicate how great the loss in useable old-irowth
habitat actually is.
Page 74 - Timber Harvest, First Paragraph, First Sentence:
We agree with the statement that only Alternatives 6, 7 and 8 will assure
the maintenance of viable populations on animals throughout the Roseburg BLM.
Page 74 - Timber Harvest, Fourth Paragraph, First Sentence:
This paragraph discusses the Tyee area and its importance to elk that presently
exist in that area. Please explain in the final impact statement why there are
no long-term provisions for retaining mature or old-growth forests beyond the
fourth decade in the Tyee area.
PNRS 820629-068-4
August 20, 1982
Page 4.
PNRS 820628-068-4
August 20, 1982
Page 5.
85
4
Pages 74-75 - Timber Harvest, First Paragraph
These two pages discuss the quantity of snags left after timber harvest and
the importance of snags in maintaining viable populations of wildlife depen-
dent on snags. The quantity of snags left, at today's rate of cut, (0.1
snag per acre) is well below that needed for viable populations of dependent
species. Two snags per acre has been shown to be the minimum number needed
to provide viable populations of those species.
Table 3-10 on page 75 indicates the preferred Alternative will provide snags
at a level that will depress the population of snag dependent species to 20-
30 % of potential. That level will not maintain viable populations of those
species. Table 3-10 also indicates that Alternative 6 and 7 might maintain
viable populations, and only Alternative 3 would surely allow viable popula-
tions to exist. It is possible and desirable to leave snags during harvest
operations. In the final impact statement, please explain why mitigative
techniques will not be implemented that will assure the continued existence
of snag dependent species.
Page 76 - Paragraph Two, First Sentence:
We agree that without mitigating prescriptions, impacts on elk populations
would be more extensive than those shown in Table 3-11, page 79. Table 3-11
is based upon forage-cover ratios generally accepted by wildlife biologists
in the Roseburg area.
Page 77 - Second Paragraph, First Sentence:
Discussed are the impacts of pre-commercial thinning on big game. Discussion
indicates that pre-commercial thinning can impede the movement of big game if
slash is unremoved. According to the DEIS, slash will not be removed, thereby,
adversely impacting big game. Please explain in the final EIS why travel
lanes will not be provided for big game or why slash will not be removed from
thinned areas.
Page 77 - Transportation System, First Paragraph, First Sentence:
The five year timber sale plan shows about three miles of road would be built
on fragile or unstable soils adjacent to streams with fishery values. If sedi-
mentation increases, the impacts would be adverse and be significant. Earlier
in the DEIS, a statement is made that road construction does lead to increased
sedimentation.
Page 78 - Fifth Paragraph, First Sentence:
QC IPlease explain why the five year timber sale plan has 26 harvest units on
O^-lglunstable soils adjacent to streams with cold water fish values. It is the
Department's belief that timber harvest should occur where fish habitat will
not be damaged. It is evident from this paragraph in the EIS that timber
sales are planned in areas that will prove harmful to fish resources.
Page 78 - Threatened and Endangered Animals
The fifth paragraph of this section indicates the five year timber sale plan
will impact habitat of nearly one half the known pairs of spotted owls. We
regard this loss as serious and of Immediate concern.
Oregon Revised Statute 496.012 says in part: "It is the policy of the State
of Oregon that wildlife shall be managed to provide the optimum recreational
and aesthetic benefits... in furtherance of this policy, the goals of wildlife
mangement are: (1) To maintain all species of wildlife at optimum levels and
prevent the serious depletion of any indigenous species."
Whether or not old-growth and spotted owl habitat has been seriously depleted
at this time may be debated but it is apparent that land management continued
on a status quo basis will seriously deplete that habitat type in the future.
The application of State law to federal land is best addressed by the legal
profession but there may be a responsibility of the BLM to consider that
statute in formulating land use plans.
85
'-14
Final impact statement, please quantify the impacts on fish that will
result from building three miles of road on fragile and unstable soils; also,
please justify those increases and adverse impacts in light of the statement
on page 78 that says: "increases in bottom sediments, according to Gibbons
and Saylo (1973), cause the most damage of all factors affecting fish life."
143
Response to comments in Letter 85.
85-1 This is beyond the scope of the EIS which is restricted to timber
management See response to comment 2-1
85-2 See response to comment 5-3.
85-3 The text has been revised in the FEIS.
85-4 Refer to DEIS, Chapter 3, page 79, for impacts on fish. Also, see
response to comment 74-3.
85-5 See response to comment 7-1.
85-6 Refer to DEIS, Chapter 3, Table 3-2, for details. Most of the loss is
due to compaction.
85-7 The text has been expanded in the FEIS, Chapter 1- Table 1-5.
85-8 Refer to Appendix C, Table C-4, for comparison of riparian areas.
None of the alternatives provides for harvesting half the timber
volume.
Alternatives 2, 3, 4, and 7 employ modified area control (DEIS,
page 124) for the riparian zones along third order and greater
streams. The sample five-year timber sale plan, as described in the
DEIS, Impacts on Animals section, page 75, indicates a yearly average
of 12 acres clearcut and 96 acres partial cut in the above areas. If
these areas were removed from the allowable cut calculation, as in
Alternatives 6, 8, and 9, an estimated decrease of 500 MCF or 3 MM
bd. ft. would occur.
85-9 The DEIS indicates impacts are insignificant. Also, see response to
comment 74-3.
85-10 Maps are available for inspection in the Roseburg District Office.
85-11 Corridor alternatives adopted or proposed by other BLM districts
which adjoin Roseburg (i.e., Coos Bay and Eugene) have been
considered and are coordinated with Roseburg District alternatives.
Effectiveness will be monitored over time.
85-12 The text has been revised in the FEIS, Chapter 3, Terrestrial
Vertebrates, Timber Harvest section.
85-13 Conflicts with operator safety requirements preclude snags frcm being
left on many harvest operations in the intensive forest management
base. Although options to leavirg snags exist (e.g., topping trees),
those options where the cut level would be reduced to the point of
changing an alternative would not be planned. Also, see response to
comment 5-3.
85-14 Refer to DEIS, Chapter 3, page 79 for impacts on fish. Also, see
response to comment 74-3
85-15 Adverse impacts can be mitigated through project design features, as
described in DEIS, Chapter 1.
SEATTLE, WASHINGTON 98101
U.S. ENVIRONMENTAL PROTECTION AGENCY
<(eo st^ R E G t O N X
v, ^^ r 1200 SIXTH AVENUE
"two? m/S 443
32
86
86-1
James E. Hart, Oi strict Manager
Roseburg District Office
Bureau of Land Management
777 NW Garden Valley Blvd
Roseburg, OR 97470
RE: Roseburg Timber Management Program DEIS
Dear Mr. Hart:
The Environmental Protection Agency (EPA) has completed reviewing the DEIS
for the Roseburg Timber Management Program (TMP). The DEIS adequately
presents the program and the various alternatives available for its
implementation.
We would like to offer the following comments on Chapter 3 (ENVIRONMENTAL
CONSEQUENCES) which may serve to improve the discussion in the Final EIS.
Checkerboard Lands Pattern
Lands under 8LM management, in the Roseburg District as well as other
western Oregon districts, are largely in a checkerboard pattern. The map
accompanying the DEIS shows these lands to be widely dispersed in a
"circle" surrounding Roseburg. This land distribution pattern creates
special problems for managing the environmental consequences of the
TMP when both the causes and the mitigating measures constantly cross and
recross the boundaries of BLM lands. Any special limitations and controls
to address this problem should be described in the Final EIS. It would
also be helpful if the Final EIS noted any cooperative arrangements or
joint actions being undertaken with adjacent land owners for managing the
boundary-crossing environmental consequences of the management program.
144
Air quality
We cannot locate the reference to a 30-35 mile distance for slash burn
plume dispersion, beyond which "(p)ollutants ... dre usually mixed by wind
and dissipated..." (citing EPA, 1978). The report cited indicates that a
100 mile distance is a more appropriate measure to evaluate plume disper-
sion and potential effects on Class I and non-attainment areas. There are
four Class I areas (Diamond Peaks, Three Sisters and Kalmiopsis Wilderness
* _ Areas, and Crater Lake National Park) and two non-attainment areas (Medford
OD"t and Eugene) within 100 miles of the Roseburg District lands. The final E1S
should discuss and evaluate the potential effects of slash burning on air
quality in these Class 1 and non-attainment areas and indicate appropriate
smoke control measures to avoid smoke intrusions in these areas.
We recommend that you consult with the Oregon DEQ for current data about
particulate emissions from slash burns and for assistance in quantifying
the effects of slash burns.
The OEIS does not discuss potential alternatives to slash burning which
may provide viable air quality control measures. Various post-harvest
management techniques should be included in the discussion of air quality
management, or this section should reference other parts of the EIS where
they may be discussed.
Human Health Effects & Potable Water Supplies
I Page 86 of the DEIS indicates that the "...number of people that could be
86" 41 directly affected by herbicide application in the planning area is small,"
I but presents no demographic or land user data to support this point. We
recommend that quantitative information be provided to support this conclu-
I sion. This discussion should include an assessment of possible herbicide
OD - 5| accumulation in drinking water supplies [the DEIS (p. 69) notes four
I municipal watersheds on BLM lands]. The FEIS should indicate whether the
oe_C| 'MP will cause or contribute to any violations of the Interim Primary
OD~0| Drinking Water Regulations in the affected water supplies.
I The final EIS should discuss and evaluate alternative vegetation manage-
ment techniques, such as on-ground spraying or hand cutting, which may
minimize unwanted environmental consequences of aerial spraying.
Finally, we recommend that you coordinate this part of the EIS with the
work now being done through the Salem District Office to prepare a DEIS
for BLM's Westside (Oregon) vegetation management program.
Water quality
Page 69 of the DEIS indicates that buffer strips are expected to minimize
herbicide drift or accidental spraying of water courses. However, Table
3-5 shows varying amounts of timber harvesting will take place In bill
strips. The two alternatives which Include no harvesting In buffer strips
show that sedimentation can be reduced by approximately 150,000 tons over
I the first decade of the program. This apparent contradiction should be
clarified, showing any relations between extent of spraying in areas
around streams, and the amount of buffer strip harvesting.
Tables 2-5 (p. 39) and 2-7 (p. 41) seem to Indicate that most major
streams within the Roseburg District suffer from severe sedimentation
problems. Timber harvesting within the District will exacerbate this
problem. The DEIS recognizes this situation but is unclear about measures
which may be implemented to minimize sedimentation and to meet and
maintain water quality standards. One control which appears viable is to
preserve, or widen as appropriate, streamside buffer strips. Table 3-5
(p. 68) indicates that extensive cuts are to be made in existing buffer
I strips. We recommend that these buffer strips not be cut, and that the
Final EIS identify and evaluate potential mitigation measures which could
be used to reduce the sedimentation problems identified in the Draft EIS.
. — I It should also indicate whether the streams currently meet the applicable
86 10l wat er quality standards and how each of the alternative timber management
^programs would affect water quality standards compliance.
EPA has rated this EIS 10-2 [LO: Lack of Objection; 2: Insufficient Infor-
mation]. We appreciate the opportunity to review the report. Should you
desire to discuss EPA's suggestions, you may contact Mr. Dick Thiel, our
Environmental Evaluation Branch Chief, at (FTS) 399-1728 or (206) 442-1728.
y£
Sincerely,
V- John R. Spencer,
Regional Adminstrator
Response to comments in Letter 86.
86-1 The DEIS, Chapter 1, describes Memoranda of Understanding,
Cooperative Agreements, Permits and other instruments appropriate for
managing the intermingled ownership pattern of the O&C lands. Also,
see response to comments 4-4, 5-3, and 58-3.
86-2 The text has been revised in the FEIS, Chapter 3, Impacts on Air
Quality section.
86-3 Alternatives to slash burning and other related issues will be
addressed in an EIS on Vegetation Management for western Oregon. The
Draft EIS is being prepared and is expected to be published later in
1983.
86-6 The timber management plan is not expected to result in violations of
the Interim Primary Drinking Water Regulations. BLM cooperates with
the Oregon Department of Environmental Quality as well as the
affected municipalities through Memoranda of Understanding, as
described in the DEIS, Chapter 1, pages 27-29.
BLM timber harvesting, road construction, chemical applications,
slash disposal and reforestation requirements meet or exceed the
Oregon Forest Practices Act standards, as indicated on page 27 of the
DEIS.
86-7 Alternative 7 in the DEIS evaluates this point. The new EIS on
Vegetation Management will specifically address a no aerial spray
alternative.
As part of BLM's planning process a determination of the number of
residences within 1/2 mile of BLM land was made. Approximately 9,600
rural residences are within the boundaries of the Roseburg District.
Of these 3,413 or 36 percent are within 1/2 mile of BLM land. Only a
few percent are affected in any given year. These are detailed in
site specific environmental assessments prepared for vegetation
management and other projects.
This issue was addressed in the FEIS, Vegetation Management with
Herbicides: Western Oregon 1978 through 1987. Refer to DEIS, Chapter
1, page 20, which incorporates the above FEIS by reference. In
addition, the new EIS on Vegetation Management will address the
issue.
86-8 Streamside buffers for water quality protection during timber
harvesting operations are different from those streamside buffers
associated with herbicide spraying. The EIS, in Appendix C, Table
C-4, identifies protective measures proposed during timber harvest
operations along streams (riparian zones). Protective stream buffers
applied during herbicide spraying operations are identified in the
DEIS, Chapter 1, page 22, Plantation Maintenance and Release section.
86-9 Alternatives 6, 8, and 9 do not include any harvest within buffer
strips. Mitigation is described in DEIS, Chapter 1. See response to
comment 5-3.
86-10 See response to comment 15-6.
90
145
/Kvj\\ United States
UUkI// Department ot
\»A/ Agriculture
Pacific
Northwest
Region
319 S.W. Pine
P. 0. Box 3623
Portland, OR 32208.
1950
August 20, 1982
Mr. James E. Hart, District Manager
Rojeburg District Office
777 N.W. Garden Valley Blvd.
Roseburg, OR 97470
Dear Mr. Hart:
We appreciate this opportunity to comment on the Roseburg Timber
Management Draft Environmental Impact Statement. The Umpqua National
Forest and Roseburg District are linked by several mutual management
concerns and the opportunity to address them. There is also a shared
opportunity to be responsive to the public in the management of resources
which seek habitat rather than heed administrative boundaries.
Significant among these are elk and northern spotted owl, the latter
being inextricably linked to old-growth forests.
We are concerned that, though there has been much coordination between
Forest and Bureau of Land Management Roseburg District personnel, the
proposed action does not reflect this coordination or recognize that
certain decisions about District management affect resource management on
the Umpqua National Forest.
The number of northern spotted owl pairs recommended for testing in the
Umpqua National Forest planning process is based on the Oregon
1 Interagency Spotted Owl Management Plan. Roseburg's proposal to not
90 il mana 9 e i n accordance with recommendations of that plan may have
I impl i cations on the number recommended for the Umpqua.
90-2|
Similarly, the District's planned reduction in elk habitat could place a
burden on National Forest habitat resources. We would like to have these
implications considered in your decision.
We also have an interest in methods of analysis you have used which may
be applicable to National Forests and add consistency to our planning.
Of particular interest are estimation techniques used in assessing water
resource effects and your rationale linking mitigation provisions of the
several alternatives and Federal law.
Mr. James E. Hart
Another area of concern is the timber growth prediction attributed to
fertilization as it may be interpreted to apply on National Forest
lands. Although we agree that this practice can increase yields we have
little information on response from the Umpqua National Forest. Umpqua
yield tables, therefore, are necessarily more conservative.
We look forward to continued close cooperation with the Roseburg District
in formulating the Umpqua Forest plan. Together, the two plans will
provide the major thrust for Federal land management in the next decade
in Douglas County.
Sincerely,
^*£.
EFF M. SIRMON
Regional Forester
FS-62CO-1 1 (8-80)
91
Response to comments in Letter 90.
90-1 The text has been revised in the FEIS, Chapter 3, Impacts on Animals
section, indicating that if BUI does not manage for the number of
pairs allocated to it in the Spotted Owl Management Plan, the unmet
portion would revert to the Oregon Endangered Species Task Force to
consider possible reapportionment.
INDUSTRIAL FORESTRY ASSOCIATION
2680 NO PACIFIC HIGHWAY
MEDFORD. OREGON 97501
-.11 u t
90-2 The text has been revised in the FEIS, Chapter 3, Impacts on Animals
section.
91-1
91 2
James E. Hart, District Man
Bureau of Land Management
777 NW Garden Valley Roulevard
Roseburg, Oregon 97470
Dear Jim,
I am Southwest Oregon Di
located in Med ford at 2680 North Paci fie Highway .
about 90 timber industry comj
which purchase timber on the Roseburg mil District.
I would like to thank the BLM for t 1 '
the adequacy of the Roseburg Disl
attempt to predict environmental impacts resu
actions. The interdisciplinary
efforts.
in extensive effort, however, i
as a guide to decision makers. Sever.il are
leading and may confuse decision make]
hensive timber management plan which will I
of the Roseburg study area.
To begin with the analysis of the cui :
adequate. Comparing it with the other seven alternatives is liki
apples and oranges. Alternative b use: . the old stand i
and yield data, while the other
native 3 were chosen as the basic, of the future t
assume you would use the new invi
now proven to be incorrect. Alt,
now proven to De incorrect, ttitern
using the new inventoi
compare all eight alternatives. II |ust
Alternative (#4) is actually a proposed
Roseburg BLM District.
Another unclear and misle
Page 23 indicates the greatest habitat modil
5. On page 24, table I
modification. Table 1-5
to a greater extent than Alternative 1, even
acres than Alternative 1 and prt ut .
146
James f .
Page 2
Hnrt , Di
James I
Page 3
913
: . ■ ■ :
il will
■
■ ■■
■
i sm or
■
■
Bed on t .i 1 1
Ibro;ni No ment ion
15 made i on for
cavit locument, de-
cadent, sna considered estheti ng. An
attempt should be made in tin , of impacts
relat ii ■
On pages 60, 61 , toil 62 an atti I o desci ibe the economic
of t i ient on Local econi i n, In this in IS, the data i
sented in 1976-1978 dollars, for I 1 n't understand how
predirt Spotted Owl population levels i" fin- tOth decade, yet we can'l
economic discussion presented in current dollar values. It seems to me m
current economic data would be more meaningful to a decision maker. In the n !'■
it would he helpful to know if the figure-, in Table 2-26 (Economic Affects of
I isheries, Hunting, and Recreation) and the summary on page 62 are also in 1976-
1978 dollars.
91 5
In addition to the above general thoughts, which I presented in oral testi-
mony at the August 18th public hearing, I would like to add the following more
specific concerns and recommendations for your consideration in evaluating the
adeguacy of the DEIS.
1. Alternal , Linkage to the new policy on BLM 0&[ Lands,
Onl) alternatives 1 and to determining harvest based on
1 i mi ted landbase withdrawals for other resources.
I Recommendat i ons : All alternatives should be redeveloped based on the new BLM
planning criteria. If necessary, a new proposed action should be developed
either in the final EIS or a new Drat!
2. Departurealternatives, '[though actually calculated, were given essent-
ially footnote coverage in the DEIS. NEPA requires the agency to fully
1 1 ill alternatives even if they violate current law or policy. The
description in the EIS that the departure analysis is not "useful enough"
te. It is obvious that significant increases in current and
md growth is possible with a departure as compared to
the pro;
^- — I Recommendations: fully analyze several v
y | — * |socioeconomital and environmental effects
able departure
in the FEIS.
.1 ternat lves for their
91-8
I
under the A.C.E. corn i ,
at ion valu
■
uea only gi vi
■
value of the land. I
is worth when sold in the market p
mkings. One question wi
higher S.E.V. regimes, why was the Li
the preferred alternal
IThe price assumptions are overly optimistic interims of futun
it , the current price is about one-h i
for timber values also appear to be overly
„«/>|^' " 1( cos *- factors
9l~*10| ' l than has been recent ex;.
|on Industry lands, or (2 tiated.
Recommendation: Completely redo the economic analysis to reflect the true cur-
rent costs and revenues generated by management and evaluate returns exclusive
of the ACE effect.
5. We are extremely concerned at the BLMS proposal to reduce the landbase
by some 44,000 acres, increase the management intensity through higher bud-
get dollars, and thereby mere i. While we
approve strongly of intei 'ment and the leadei
shows in this area, we are concerned about the use of intensive management
to trade away acres for unsubstantiated other resource use3. The increase
in budgets required to be successful m this program will likely not be
there in the future. Thi entire timber pro-
gram predicated on some very shaky i r>s. One solution to
the dilema is to alter the forest management intensity to reflect better
budget expectations and make up the loss in production from additional al-
locations of timberland from nontimbei
I Recommendation: Reformulate the alternatives into proposed programs which are
more in line with realistic budget assumptions, and clearly display what the
increases in budgets expected are for each increment of additional allowable
Sincerely yours,
D i r>K-.^rl U C~ 1 -l~ .• '
Richard H. Felgenhou
District forester
Response to comments in Letter 91
91-1 Council on Environmental Quality {CBQ) Regulations (40 CFR
1502.14(d)) require a No Action Alternative to be included in
environmental impact analysis.
91-6 The FEIS includes a new Preferred Alternative (Alternative 9).
Also, see response to comment 12-1.
91-7 Refer to Appendix B, Results of Scoping. Also, see response to
comment 78-4 .
91-2 The text has been revised in the FEIS, Chapter 1, Comparison of
Impacts. Differences relating to the amount of old growth existing at
the end of the first decade under Alternatives 1 and 5 are explained
in the DEIS, Chapter 3. Table 3-8.
91-3 See response to common issue 1.
91-4 Although positive effects on cavity dweller habitat would result from
herbicide treatment to broadleaf species, such treatment would not
provide significant wildlife benefits due to the scattered
distribution of broadleaf species in the Roseburg District.
91-8 See response to comment 68-19.
91-9 Average sales value per M bd. ft. for timber sold by the Roseburg
District was $260 in FY 1981 and S94 in FY 1982. These baselines have
been added to Appendix B, Table B-2.
91-10 See response to common issue 5.
91-11 See response to common issue 2.
91-5 Table 2-26 has been revised in the FEIS to include a footnote which
indicates that the estimates of personal earnings reported are
adjusted to the average wage and price level which prevailed in
Oregon between 1976 and 1978. In order to sum the results of Tables
2-25 and 2-26 (page 62, DEIS) the estimates of personal earning must
be in dollars of the same period. The most recent year in which data
were available for all resource categories evaluated in the plan was
1978.
93
147
984 Lincoln
Eugene, Ore. 97401
Roseburg District Manager
Roseburg District Office
777 N.W. Garden Valley Blvd.
Roseburg, Ore. 97470
Following are my Garments on the Roseburg Timber Management Environmental
Impact Statement.
I am continually appalled tl^at the BLM could write an EIS so curiously
descriptive and graphic concerning the impacts to wildlife, and yet propose
to make those very decisions having the worst effect. The EIS admits that
continuing timber management at Uae proposed level will ruin forest diversity;
that elk survival cover will be greatly reduced, leading to a 20% decline in
the population; that mortality salvage will eliminate snags; that the preferred
alternative will cause a 34% decline in old growth after one decade, and a
ridiculous 71% decline after a century; that the Tyee area contains none of the
old growth management, et cetera.
It defies comprehension for the Roseburg District to say that the spotted
owl is a potential candidate for threatened and endangered status, yet propose
an alternative that does not aid its long term cliances for survival. Likewise
with clioosing an alternative that follows tlie Forestry Plan for Oregon, but
does not follow the Oregon Department of Fish and Wildlife recommendations.
Nothing in the O&C Act requires this sort of donu-nant use. It is especially
ridiculous to raise the allowable cut when, due to the deep recession, billions
of BLM board feet are sold but not yet cut. Simply selling more will only further
93-1
depress an already disastrous market.
When will foresters realize that wildlife and tunber management are not
separate disciplines; tliat both rest, and
tliat it is not good enough to consign wildlife to the
inant timber program. The excuse has always been the O&C
does not mention wildlife, BLM need not worry about
attitude. Forest management is not synonymous with timber management.
Tlie O&C Act does mention watershed management. Amajor c
management is riparian zone preservation, which fares rather . ■
preferred alternative. It is the first and second order streams, the beginnings
of the major rivers, whose riparian areas are not being protected at all.
The EIS, like many of its ilk, goes into gruesome detail on wildol
which is laudatory. But it never explains the forestry program in hurt;.'
It is not necessary to include a detailed and complicated analysis of
allowable cut's derivation. But it is important to explain truthfully how the
allowable cut is derived; the use of the allowable cut effect; and the rationale
for the allowable cut. Itone of these things are done. There is no explana-
tion for why tlie cut goes up so highly in this EIS.
In light of the fact that nutters are not settled on Coos Bay, and that a
corridor system may be the only viable way to settle the remaining old growth
into a workable system, I shoula think it liastyi to espouse an alterr^
like this one.
Sincerely,
Cameron La Follette
Response to comments in Letter 93.
93-1 The text has been revised in the FEIS, Appendix C, by the addition of
Figure C-2. Also, see response to comment 16-40.
94
UNITED STATES DEPARTMENT Of COMfVlf RCf
Nation.il Oceanic and Atmosphc
September 17, 1982
District Manager
Bureau of Land Management
Department of the Interior
777 NW Garden View
Roseburg Boulevard
Roseburg, Oregon 97470
Dear Sir:
This is in reference to your draf f envii
entitled "Roseburg Timber Managenent." The ei
National Oceanic and Atmospheric Administration are
consideration.
Thank you for giving us an op;
which we hope will he of assistance to you. We would d|
four copies of the final environmental impacl
Sincerely,
Joyce M. Wood
Director
Office ol
Enclosure: Memo from: Dale R. Evans
National Marine Fisheries
^
148
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
,
if-
Sub;.
cor.:
The
doc
COUl-i :rces.
ut could ent. in
For caused by lai
■ order
total of ton :.r of the soi seburg
SYUs are ( I m d Problem soils (Table 2-4) , i
In other cases, a small
is dam could block access to all ■ liomous
tal i roi i to I
;ent document.
Specific O :
-.. .1 Animals. There is no mention of possil of the
y^T _ l posed action would increase water yield
' rsheds, there must be some impact on fish.
Q4-OI Ic 1-5. Summary of Imp
^" ^1 ts en fish habitat.
The table does not include an
Pa 1 e 26 - Federal Agenel.-
94-3
94-4
94-5
response
md anadtomou
Resour he Coastal Zoi
Environ in d makes recoi
Il DIBOUS f ish*-r . n ana >
Wildlife Coordination Act.
Soils. Table 2-4, Fragile and Problem Soil- .
Pages 34-36
to Figure 2-2, • . Q f the table and I
correspond, even considering the <
compare and
age 46, Table 2-11
_ Salmonid Fish Habitat and Papula*: i
i 'ual miles of fish habitat. Some habil
by more than om
year.
94-6
im and downstr
r quality and quant
: for fish mig ratioi
should i :. impact on fish caused by the propos<
quant i :
I Page 77. Fish . Whi
and the section on ;
the consequent i .rious altern.
discussed.
larly concerned for the n
buffer strips tor streams. We strongly urge inc
action (or into whichever alternative ii
provide for protection and enhancement of fish i
integrity oi I
the proposed
which
irea.
11
I Special attention should be given to bank protection on first and second order
as well as higher order streams to prevent sed
protection for all Class I streams against sedimentation and in-.-
temperatures.
Inasmuch as future declines in timber auppli 61), it
would seem prudent to protect alternative economic resources as much
possible.
^^^
Response to comments in Letter 94
94-1 See response to comment 74-3
94-2 See response to comment 74-3.
94-3 Tiie text has been revised in the FEIS, Chapter 1, Interrelationships
section
94-4 The text has been revised in the FEIS. Chapter 2.
94-5 The total miles of salmonid habitat are indicated in the DEIS,
Chapter 3, page 77. it can also be determined from Chapter 2, Table
2-11, by adding the miles of 8LM habitat for resident trout.
94-6 See response to comment 85-4.
94-7 Refer to DEIS Chapter 3, page 79. Also, see response to comment
74-3.
94-8 Refer to DEIS, Appendix C, Table C-4.
149
LIST OF AGENCIES, ORGANIZATIONS AND PERSONS TO WHOM
COPIES OF THE STATEMENT ARE SENT
Comments on the draft environmental statement were
requested from the following:
Federal Agencies
Advisory Council on Historic Preservation
Department of Agriculture
Forest Service
Soil Conservation Service
Department of Commerce
National Marine Fisheries Service
Department of Defense
U.S. Army Corps of Engineers
Department of Energy
Region X
Department of the Interior
Fish and Wildlife Service
Geological Survey
National Park Service
Bureau of Mines
Bureau of Reclamation
Small Business Administration
Environmental Protection Agency
State and Local Government
Oregon State Clearinghouse
Oregon Regional Clearinghouses
Lane Council of Governments
Umpqua Regional Council of Governments
Rogue Valley Council of Governments
Oregon State Historic Preservation Officer
Boards of County Commissioners
Douglas County
Copies of this environmental impact statement will be
available for public inspection at the following BLM offices:
Interest Groups (partial listing)
American Forest Institute
Associated Oregon Industries
Association of O&C Counties
Cascade Holistic Economic Consultants
Friends of the Earth
Industrial Forestry Association
Izaak Walton League
Natural Resource Defense Council
National Wildlife Federation
Northwest Environmental Defense Center
North West Timber Association
Oregon Environmental Council
Oregon Natural Heritage Program
Oregon Student Public Interest Research Group
Oregon Wilderness Coalition
Sierra Club
Southern Oregon Citizens Against Toxic Sprays
Southern Oregon Resource Alliance
Southern Oregon Timber Industries Association
The Wilderness Society
Western Forest Industries Association
Wildlife Management Institute
Roseburg District Office
777 NW Garden Valley Blvd.
Roseburg, Oregon 97470
Phone (503) 672-4491
Washington Office of Public Affairs
18th and C Streets
Washington, D.C. 20240
Phone (202) 343-5717
Oregon State Public Affairs Office
825 N.E. Multnomah
P.O. Box 2965
Portland, Oregon 97208
Phone (503) 231-6277
Reading copies will be placed in the following libraries: Portland State University, Portand; Oregon State University,
Corvallis; University of Oregon, Eugene; Lane Community College, Eugene; and Umpqua Community College,
Roseburg; and public libraries in Salem, Canyonville, Drain, Glendale, Myrtle Creek, Riddle, Roseburg, Winston and
Yoncalla.
Copies of the final EIS are sent to each person, organization or agency commenting on or receiving copies of the draft
document.
150
LIST OF PREPARERS
While individuals have primary responsibility for preparing sections of an EIS, the document is an
interdisciplinary team effort. In addition, internal review of the document occurs throughout preparation.
Specialists at the District and State Office levels of the Bureau both review the analysis and supply
information. Contributions by individual preparers may be subject to revision by other BLM specialists and
by management during the internal review process.
Name
Dick Bonn
D. F. Buck, Jr.
L. D. Hamilton
Primary Responsibility
Discipline
Team Leader, Soils, Human Biologist
Health
Air, Water, Climate, Geology Soil Scientist
Technical Coordinator/Editor Geography
Related Professional
Experience
4-1/2 years BLM (Environmental
Specialist) Portland, Oreg.
11 years SCS
2-1/2 years (Biologist) Watershed
& River basin, Columbus, Ohio.
2-1/2 years (Biologist) Watersheds
Richmond, VA.
4 years (Biologist & Recreation)
Albany, Oreg.
2 years (Soil Conservationist)
Harrisburg, Oreg.
5 years BLM (Soil Scientist,
Environmental Protection
Specialist)
11 years (Outdoor Recreation
Planner, Environmental Protection
Specialist) moved to Colorado,
March 1982.
Phillip D. Havens Fisheries & Wildlife
Jeanne Johnson Editorial Assistant
R. Michael Martin Socioeconomics
Wildlife Biology 18 years (Wildlife Biologist)
Joseph Ross
Recreation, Cultural
Resources, Wilderness, Areas
of Critical Environmental
Concern, Special Areas,
Visual Resources and Energy.
R. Gregg Simmons Description of the Proposed
Action and Alternatives,
Vegetation
Administrative
Secretary
Economics
Recreation
Forest
Management
7 years BLM (Secretary, Editorial
Assistant
6 years (Economist)
8 years (Forestry Technician,
Biological Information Specialist,
Outdoor Recreation Planner)
8 years BLM (Forester)
5 years Eugene, Oreg.
3 years Portland, Oreg.
151
Roseburg District Personnel Contributing Substantial Input
Name Primary Responsibility Discipline
Related Professional
Experience
Robert L. Alverts
Stewart H. Avery
Robert W. Bright
Planning coordination, Forest
information supply, document Management
review
Information supply, document Forest Engineering
review
Information supply, document Forest
review Management
Bennie C. Hobbs Information supply, document Forest
review Management
Dennis E. Hutchison Soils, Air, Water information,
document review
Joseph B. Lint
John R. Norlin
Wildlife information,
document review
Forestry information,
document review
Resource
Management (Soil
Science)
Wildlife Biology
Forest
Management
Franklin M. Oliver Fisheries information,
document review
David R. Palmer
Robert A. Smith
Forestry information,
document review
Fish Biology
Forest
Management
Information supply, document Forest
review Management
16 years BLM (Forester, Area
Manager, Planning &
Environmental Coordination)
7 years Medford
4 years Burns
5 years Roseburg
25 years BLM (Forester, District
Engineer, Resource Manager,
Area Manager)
5 years Medford
20 years Roseburg
21 years BLM (Forester, Planning
Coordinator, Area Manager)
16 years Roseburg
5 years Susanville
13 years BLM (Forester, Timber
Manager, Area Manager)
10 years Eugene
3 years Roseburg
14 years (10 SCS, 4 BLM)
8 years Midwest and East
2 years Idaho
4 years Roseburg
8 years BLM (Biologist)
4 years Coeur 'd Alene
4 years Roseburg
25 years (5 BIA, 20 BLM) Forester,
Timber Manager, Realty Spec,
Timber Management Spec.)
3 years Midwest
2 years E. Wash.
5 years Tillamook
15 years Roseburg
18 years (5 years Oregon
Department of Fish & Wildlife, 13
years BLM, Fish Biologist)
18 years Roseburg
7 years BLM (Forester)
7 years Roseburg
32 years BLM (Forest and Range
Management, Fire Control,
Area Manager)
14 years Alaska
3 years Burns
15 years Roseburg
153
Appendices
Page
Appendix A — O&C Forest Resources Policy to be Used in Developing Plans
for BLM-administered Forest Lands in Western Oregon 154
Appendix B — Results of Scoping 1 59
Appendix C — Development of the Proposed Action and Alternatives 1 65
Appendix D — Wildlife 1 73
Appendix E — Alteration of Wildlife Habitat on BLM-administered
Forest Land 1 79
Appendix F — Predicted Alteration of Wildlife Habitat on All Forest
Lands in the EIS Area 1 84
154
Appendix A
O&C Forest Resources Policy
to be Used in Developing Plans
for BLM Administered Forest
Lands in Western Oregon
This statement sets forth BLM policy for
management of the Revested Oregon and
California (O&C) Railroad and reconveyed Coos
Bay Wagon Road Grant lands situated in the State
of Oregon. It reflects the provisions of the Act of
August 28, 1937 (O&C Act), and the effects of
other relevant legislation and Executive Orders.
The BLM manages 2.1 million acres of O&C lands
in western Oregon. The revenues and employment
generated by timber sales, conversion of timber to
wood products, and other marketable values
derived from these lands significantly affect the
State and local economies. It is further recognized
that public use of these lands through
consumptive and non-consumptive recreation,
including sport hunting and sport and commercial
harvest of salmon and steelhead produced in
streams on the O&C lands, also contributes to the
local and State economies. The primary objectives
of the management program on the O&C lands are
to manage for a high-level and sustained yield
output of wood products needed to contribute to
the economic stability of the local communities
and industries, and to provide for other land uses
as established in the O&C Act and other
legislation.
The following principles will guide BLM in
managing the forest resources on O&C lands:
1. Resource management plans or management
framework plans as developed through the land-
use planning process shall constitute the primary
guides for carrying out legislative mandates and
Bureau policies.
2. All O&C land administered by BLM in western
Oregon will be classified according to the Timber
Production Capability Classification. Lands
classified as suitable for timber production shall
be managed for timber and wood product
production, to the extent possible, under the
requirements of law. Lands classified as
nonsuitable for timber producton shall be
allocated to the fullest extent possible to meet the
needs for non-timber public land uses. Where
nonsuitable lands cannot adequately provide for
other uses set forth in the O&C Act and other
applicable legislation and Executive Orders,
suitable lands may be managed to meet the needs
for the following:
a. Maintenance of water quality in accordance
with Federal and State standards. Timber
harvesting may be restricted or excluded only in
areas where mitigating measures will not maintain
water quality standards.
b. Protection of wetlands, including riparian
zones. Timber harvesting may be restricted or
excluded only in areas where mitigating measures
will not be effective.
c. Conservation of specifically identified habitats
for federally listed, threatened and endangered
species. Timber harvesting may be restricted or
excluded only in areas where mitigating measures
will not be effective.
d. Research and development pertinent to the
management of the land resources. Timber
harvesting may be restricted or excluded only in
areas where mitigating measures will not maintain
resource values, and research is assessing these
values: timber harvesting may be restricted or
excluded pending the research conclusions.
e. Consideration of State goals and objectives
concerning State-listed, threatened and
endangered species in land-use planning and
management. Restrictions may be utilized to
achieve the habitat objectives developed from the
BLM plans.
f. Consideration of habitat needs of native species.
Restriction of timber harvest may be considered
when these habitat needs cannot be met through
established timber harvest practices.
g. Protection of developed high-value recreation
areas, including the visual quality of significant
scenic areas. Restriction or exclusion of timber
harvest may be considered in the protection of
established recreation facilities. Timber harvest
may be restricted in the protection of scenic areas
only where mitigating measures will not prove
effective.
3. The allowable cut determination shall be based
on a nondeclining harvest level over time.
Departures from the nondeclining harvest level
may be permitted in either direction. Any
increases shall not exceed the long-term
sustained yield capacity of the land; decreases
shall be economically and/or biologically justified
and timed so as to minimize impacts on
dependent industries and local economies.
The Serai Stage
Distribution Concept
The mid-age and old growth stands remaining
today are the result of complex interactions
between plants and animals over time. Evidence
points towards the simultaneous evolution of
these plants and animals. Yet, the exact
functioning and purpose of many of these
interactions have not yet been studied in depth.
For example, the mechanisms for nitrogen fixation
have only been identified within the past decade.
155
Additionally, there are indications that mycorrhizal
inoculation by rodents may be critical to
plantation establishment and survival in some
instances (Franklin et al. 1981). There are many
unknowns regarding which portions of this
interacting web, if any, must be replicated by
management if long-term timber production is to
be maintained at high levels. What is known,
however, is that the timber management program
would liquidate the remaining old growth stands
in a relatively short time if unconstrained.
Seed zones are accepted as generally
encompassing a geographic area within which the
factors affecting reforestation and subsequent
growth are relatively homogenous. Mid-age and
old-growth timber in areas allocated to long-term
timber productivity; habitat for old growth related
species, including the northern spotted owl;
riparian habitat; and high scenic quality provides
adequate coverage of seed zones in the Roseburg
District (see Appendix C, Modified Area Control).
For all districts in western Oregon most seed
zones where old growth currently exists are
adequately covered. Table A-1 and Figure A-1
indicate the seed zones which cover the five
western Oregon district boundaries.
Table A-1 Tree Seed Zones by
Elevation in Western Oregon
Zone
Elevation
District
053
1,500
- 2,000
Salem
061
1,000
- 1,500
Salem
061
1.500
- 2,000
Salem
061
2,000
-2,500
Salem
062
500
- 1,000
Coos Bay
062
500
- 1 .000
Coos Bay
062
1,000
- 1,500
Eugene
062
1,000
- 1,500
Coos Bay
062
1,500
- 2,000
Coos Bay
071
500
- 1 .000
Coos Bay
071
500
- 1,000
Coos Bay
071
1,000
- 1,500
Coos Bay
071
1,000
- 1.500
Coos Bay
071
1,500
- 2,000
Coos Bay
071
1,500
- 2,000
Coos Bay
071
2,000
- 2,500
Coos Bay
072
500
- 1,000
Coos Bay
072
500
- 1,000
Coos Bay
072
1,000
- 1,500
Coos Bay
072
1,000
- 1,500
Coos Bay
072
1.500
- 2,000
Coos Bay
072
1.500
- 2,000
Coos Bay
072
2,000
- 2,500
Coos Bay
072
2,000
- 2,500
Coos Bay
072
2,500
- 3,000
Coos Bay
072
2,500
- 3,000
Coos Bay
251
1,500
- 2,000
Salem
252
500
- 1.000
Coos Bay
252
500 ■
- 1,000
Roseburg
252
500 ■
- 1,000
Eugene
252
1.000
- 1,500
Eugene
252
1.000
- 1,500
Eugene
252
1,000-
- 1,500
Roseburg
252
1.500-
• 2,000
Salem
270
500 -
■ 1 ,000
Roseburg
270
1,000 -
1,500
Roseburg
270
1,000 -
■ 1,500
Roseburg
270
1,500 -
■ 2,000
Roseburg
270
2,000-
2.500
Roseburg
270
2,500-
■ 3,000
Medford
452
1,500 -
2,000
Salem
452
3,000 -
■3.500
Salem
452
3,500 -
■4,000
Salem
461
1,000-
1,500
Salem
461
1.500-
• 2,000
Salem
461
2,000 -
■2,500
Salem
461
2,500 -
3,000
Salem
461
3.000 -
3,500
Salem
461
3.500-
4,000
Salem
462
1,500-
2,000
Salem
481
1.500 -
2.000
Eugene
481
2,000 -
2,500
Eugene
481
2,500-
3,000
Eugene
491
500-
1,000
Roseburg
491
1,000-
1,500
Roseburg
491
1,500-
2,000
Roseburg
491
2.000-
2,500
Roseburg
491
2.500-
3,000
Roseburg
491
3,000 -
3,500
Roseburg
491
3,500 -
4,000
Roseburg
492
1.000 -
1,500
Roseburg
492
1.500-
2,000
Roseburg
492
2.000-
2,500
Roseburg
492
2,500-
3,000
Roseburg
492
3,000 -
3,500
Roseburg
492
3.500-
4,000
Medford
051
053
S
U S DEPARTMENT OF THE INTERIOR
S*\
BUREAU OF LAND MANAGEMENT
052
R J
)
(
061
042
451
'252
262
471
k
452
M
461
462
[463
L
052
472
071
North Bend
Coos Boy
I
072
CO
O
081
o
082
090
®<
©
482
481
491
R 10 S E B U R
!) Roseburg
492
512
FIGURE A-1
WESTERN OREGON TREE SEED ZONES
501
502
D
511
701 D
721
Scale 1:1,000.000
261 Seed Zones Numbers
^^ Seed Zones Boundary
159
Appendix B
Results of Scoping
Scoping Meeting
On October 19, 1981, as part of BLM's land
use planning process, a public meeting was held
at the Roseburg District Office to discuss
important issues and alternatives that should be
addressed in the Environmental Impact Statement
(EIS) for the Douglas-South Umpqua Timber
Management Plan.
Participants in the meeting suggested 19 different
alternatives for consideration in the EIS. The
alternatives suggested, and BLM's analysis of their
usefulness and relevance to the EIS process, are
summarized as follows:
1. Maximum Timber Production. This alternative
would modify land use Alternative "A" as
described in the Preferred Land Use Alternative
Summary brochure, by providing full timber
harvest in riparian areas and reducing visual
buffers around recreation areas. It established one
end of a range of alternatives for analysis in the
EIS.
2. Maximum Timber Production Without
Economic Constraints. This alternative would
modify Alternative 1 by including all intensive
timber management practices that are technically
feasible, whether or not they were cost effective.
Upon analysis, BLM concluded that all technically
feasible practices were cost effective and thus
were automatically included in Alternative 1.
3. Preferred Alternative Without Old Growth
Habitat. This would vary from the Preferred by
including the old-growth habitat (spotted owl
areas, old growth blocks and 80-acre blocks) in
the intensive timber management base. This
defines an analytically useful and relevant land
use allocation alternative between Alternative 1
and the preferred alternative.
4. Preferred Alternative but Include Spotted Owl
Areas in Allowable Cut Computation. This
alternative would not permit, during the plan
period (decade), cutting of the spotted owl areas
protected in the Preferred; but the allowable cut
would be calculated as if that land were available
for timber harvest. This would offer little analytical
utility as it would simply propose a somewhat
faster rate of timber harvest on the preferred land
base, varying all impacts that are strictly
dependent on the rate of cutting (e.g., economic
benefits, erosion and sediment yield).
5. Review Wildlife Mitigating Measures. The thrust
of this alternative was to obtain a higher timber
harvest than the preferred alternative by addition
of measures to mitigate impacts on wildlife with
less reductions in potential timber harvest.
Analysis after the meeting led to the conclusion
that the preferred alternative included all feasible
measures that would achieve higher timber
harvest and meet the wildlife goals.
6. Strong Emphasis on Protection of Natural and
Cultural Resources. This would be similar to
Alternative "D" in the Preferred Land Use
Alternative Summary Brochure, but modified to
exclude intensive forest management practices
which enhance timber yield. This includes
protection of a variety of wildlife habitats, sensitive
botanical species, cultural resources, visual
resources, research natural areas, riparian areas
and undeveloped recreation activities and
facilities.
Approximately 263, 700 1 acres of commercial
forest land would be managed on a 60-year
minimum harvest age, although no intensive
management practices which enhance timber
yield would be applied to harvested areas after
planting. Fifteen year spacing between harvest
areas would be employed. An additional 127,400
acres of commercial forest land would be
withdrawn from the allowable cut base to protect
the resources listed above. Harvest from these
areas would be allowed only when directly
benefitting the protected resources.
7. Full Ecosystem. This alternative is intended to
emphasize the allocation of land for protection of
wildlife habitat diversity and related values.
Alternative 6 encompasses this approach.
8. Maintain Old-Growth Dependent Species and
Non-Declining Yield of Resources Other Than
Timber. Alternative 6 basically would achieve this
objective.
9. Limit Timber Management to Existing
Developed Land to Maintain Wildlife Habitat and
Watershed Protection. Alternative 6 would also
basically achieve this objective.
10. No Timber Harvest. This alternative would not
in any way meet the primary objective of the
timber management plan—providing a sustained
timber harvest. In addition, this alternative
received only limited support at the public
meeting.
11. The Natural Situation Before BLM Land
Management Began. This is not a realistic
alternative as no BLM management could
reestablish this situation. In addition, this
alternative received only limited support at the
public meeting.
12. Departure From Even Flow. This suggestion
assumed that first-decade departure from even-
flow would not cause a subsequent decline below
the even-flow level, for either the preferred land
base or the land base in Alternative 1 . BLM
analysis has shown, however, that it is not
possible to depart from even-flow in the first
1 Refinement since the scoping meeting has resulted in the following
breakdown for the constrained timber production base:
160
decade without causing a subsequent decline
below the even-flow level. Thus, the alternative is
not viable.
VRM (MHA-130) 49,376
Wildlife (MHA- 60) 107,180
Wildlife (MHA -250) 83,211
Wildlife (MHA -350) 22,669
13. Lower Average Minimum Harvest Size. This
alternative is identical to the preferred alternative
except that minimum harvest size and
corresponding minimum harvest age would be
reduced. The minimum average tree diameter in
stands selected for final harvest would be 1 1
inches diameter breast height (dbh) compared to
14 inches dbh under the preferred alternative. The
equivalent minimum harvest age would be 40
years instead of 50 years as in the preferred
alternative. This alternative is considered to be
analytically useful to the decisionmaker.
14. A Constant Budget. This alternative would be
expected to show whether, in the long run, a
constant budget would support the increasing use
of intensive management practices planned in the
Preferred Alternative. For the other alternatives, a
constant budget is assumed for the short term (10
year), but analysis of the long-run implications
would require making economic assumptions
extended over a time span of at least 60 years (the
time by which old growth on lands in intensive
management would be harvested). Such long-term
economic forecasts would be too conjectural to be
useful to the decisionmaker; however, a constant
dollar long-term budget will be displayed for the
preferred alternative.
15. Use of Different Computer Model for Allowable
Cut Computation. This is a relevant suggestion
which will be investigated for application to the
next cycle of allowable cut determinations, which
will begin in several years. At this stage of the
current process it is not practical for BLM to
obtain a different computer program for allowable
cut computations.
16. Economic Optimum for Timber Management.
This suggestion focused on management like that
of an industrial forest, with a goal of at least 7
percent real return on investment. The Bureau's
planning process is not oriented to defining such
an alternative, but the revenues and costs of
timber management for the preferred alternative
will be defined in the EIS.
17. Departure from Even-Flow on the Preferred
Land Base, with a Constant Budget. This would
combine Alternatives 12 and 14, which as
previously stated, are not viable or practical.
18. No Fertilization, No Herbicides, No Credit for
Genetically Improved Trees. This alternative
would exclude the use of both fertilizer and
herbicides for timber management. It would
provide for continued planting of genetically
improved trees, but the allowable cut computation
would not take credit for expected growth
increases. It is a relevant and useful alternative to
analyze.
19. No Fertilization, No Credit for Genetically
Improved Trees. This alternative would differ from
Alternative 18 only in one dimension. It would not
be analytically useful to include it in addition to
No. 18.
The above analysis concludes that five alternatives
suggested at the meeting were relevant and useful
to analyze in addition to the preferred alternative
and the No Action (continue existing
management) Alternative. These seven
alternatives display five land use bases; however,
only one (Alternative 6) represents a land use
allocation with an allowable cut level lower than
the preferred alternative. For comparative
purposes, another land use allocation alternative,
with an allowable cut level below the preferred
alternative, should be included. Alternative C,
described in the Preferred Land Use Alternative
Summary Brochure, fills this need.
The preceding summary, although organized
differently, was discussed with the Roseburg
District Multiple Use Advisory Council on October
20, 1981. The Council concurred with BLM's
review of the alternatives and the recommended
number for analysis in the EIS. There was a
suggestion to include an additional alternative that
would allocate only the best timber producing
lands to intensive timber management, leaving the
remainder to provide benefits for wildlife, water
quality, visual quality and other resources. This
approach, although not supported by the majority
of the Council, was later analyzed by BLM. In the
development of the preferred alternative, this
approach had already been adopted to the extent
possible. Its utility for meeting wildlife and related
objectives is quite limited, however, as the most
productive timber land also has the highest
productivity for certain wildlife species.
Based on the public comments, BLM analysis and
District Advisory Council recommendations, we
have concluded the EIS should analyze the
following alternatives:
1. Maximum Timber Production (Discussion Item
1)
2. Emphasis On Timber Production (Discussion
Item 3)
3. Lower Minimum Harvest Size (Discussion Item
13)
4. Proposed Action
5. No Action
6. Minimum Necessary Habitat Diversity
(Alternative C in Summary Brochure)
7. No Herbicides, Fertilizer or Allowable Cut Effect
for Genetics (Discussion Item 18)
8. Emphasis on Protection of Natural and Cultural
Resources (Discussion Item 6)
161
The public, through the EIS scoping, did an
excellent job of defining a number of issues they
believed the EIS should address.
Analysis showed that most of the issues fell within
the broad range of issues listed in the handout
used to begin the discussion at the EIS scoping
meeting. Following is a revised list of issues to be
discussed in the EIS. These are environmental
values which could be significantly impacted by
the timber management proposal or other
alternatives as seen by the public:
Air Quality - smoke management
Soils - fragile areas; erosion potential
Water - quality and quantity; impacts from
intensive management practices; municipal
watersheds; rural and domestic watersheds;
impact of adjoining landowners.
Vegetation - threatened and endangered species,
consistency with Endangered Species Act;
riparian, consequences of different protection
levels; old growth, amount and distribution;
consequences of herbicide use compared with
other vegetation management alternatives.
Fish and Wildlife - threatened and endangered
species, consistency with Endangered Species
Act; habitat diversity, impacts of intensive
management practices, difficulties/opportunities
in mixed land pattern, consequences of different
minimum harvest ages; nongame species, species
list, abundance, distribution, snag retention policy
by alternative; big game species and anadromous
fish, impacts of roads, impacts of cover removal,
impacts of intensive management practices;
northern spotted owls, decadal population levels,
possible listing as threatened/endangered species,
impacts of intensive management practices;
schedule of mitigating or enhancing practices;
consideration of non-suitable timberland for
allocation to wildlife; corridors, objectives,
benefits, consequences.
Social Conditions - consideration of adjoining
landowners.
Economic Conditions - public revenue; personal
income; employment; dependent communities;
funding mechanisms; benefit/cost relationships;
opportunity costs of management strategies.
Recreation - economic basis for recreation
opportunity, including hunting and fishing.
Visual Resources - difficulties/opportunities in
mixed land pattern; consideration of adjoining
landowners.
Cultural Resources - protection of sites
Human Health - impacts of herbicides
Areas of Critical Environmental Concern (ACECs)
Intensive Forest Management Practices - genetic
tree improvement; use of different silvicultural
systems; consideration of non-suitable forestland
for other uses; volume contribution of intensive
practices; limitations on size and timing of
clearcuts; description of current intensive
practices and proposed practices; description of
allowable cut calculations; display of yield
equations.
Several topics were surfaced as issues for
discussion. Although monitoring was suggested
as an issue, it is not practical to develop a realistic
monitoring plan for each alternative in the EIS. A
full monitoring plan will be developed and
included as an appendix to the decision document
to be prepared after completion of the EIS.
Some additional aspects of economic analysis
were suggested. It is felt that the topic list under
economics is a broad framework and other items
suggested as economic issues are encompassed
within this framework.
Near the end of the meeting, the audience was
asked for its preference on meetings which could
be held during the public comment period on the
draft EIS. An unstructured public meeting and/or
a formal hearing were offered for discussion. The
response favored both kinds of sessions, although
opinions were mixed on the issue. A portion of the
group preferred no meetings at all, remarking that
written comments should be more than adequate.
Scoping Correspondence
Subsequent to the discussion of alternatives
with the Roseburg District Multiple Use Advisory
Council, two letters were received. One letter
suggested an alternative which assumes the
average management intensity and departs above
the long-run sustained yield (LRSY). Although the
LRSY would be substantially lower than for other
alternatives, there would be surplus old growth
volume permitting harvest above LRSY. Under the
intensity of management in the preferred
alternative there would be no available surplus
volume. Surplus volume may be created by using
the above suggested assumptions which constrain
the sustainable harvest level. Including an
alternative in the EIS to "create" surplus inventory
in such a way was not considered useful enough
analytically, or to the decisionmaker, to warrant
the resultant increased complexity of the EIS.
The other letter proposed a departure alternative
that would increase the annual sale program in the
first two or three decades after which the harvest
level would be allowed to drop by no more than 5
percent below the even-flow level. It suggested
that this analysis be applied to the maximum
timber land base (Alternative 1), the maximum
timber base with provisions for spotted owls
(Alternative 2) and the preferred alternative land
use allocation (Alternative 4).
162
Although it is interesting to analyze the effects of
these three alternatives on harvest levels,
inclusion of them as full alternatives in the EIS
would make the EIS very cumbersome and add
little dimension to the analysis of impacts other
than socioeconomic impacts. Accordingly, they
are not included in the EIS, but the resultant
harvest levels have been computed. The annual
timber sale programs (using a two decade
increase with a 5 percent decline below the
evenflow level in succeeding decades) are shown
below in million board feet:
Decade
Alt. 1
Alt. 2
Alt. 4
1
329
303
283
2
329
303
283
3+
274
254
237
Economic Efficiency Discussion
During the EIS scoping process four economic
analyses were requested by members of the
public. The DEIS presented four different looks at
the Original Proposed Action (Alt. 4) from an
economic perspective. In response to comments
received, these analyses are expanded where
clarity was lacking in the DEIS and abbreviated
where a summary of findings would suffice. The
substantive change is to supplement projections
of growth rates in the value of timber adjusted for
inflation with two baseline price levels. The
average sales value of timber on the Roseburg
District in Fiscal Year 1981 (FY 81) was $260 per M
bd. ft. The average value for fiscal year 1982 was
$94 per M bd. ft.
Economic Efficiency of the Timber Management
Program in the New Preferred Alternative (Alt. 9).
The timber management programs in both the
Original Proposed Action and the Preferred
Alternative would yield $6.72 in timber sale
receipts for every dollar of costs at the FY 81 sales
value of $260 per M bd. ft. Each program would
yield $2.43 in timber sale receipts for each dollar
spent at the FY 82 sales value of $94 per M bd. ft.
Table B-1 identifies for Alternatives 4 and 9 the
annualized costs of major program elements for
fiscal years 1984-93. The district's proposed
budget for FY 83 is displayed for reference.
Recognize two important facts when comparing
budgets in the alternatives with dollars
programmed for FY 83. Since BLM has accepted
responsibility for prescribed burning on the
district lands, fire management costs will increase
substantially (with any alternative) in the new plan
over the amount budgeted for FY 83. Similarly,
timber management costs rise beginning in FY 84
even if programmed output is held constant
(Alternative 5). This reflects the fact that the
district in 1984 would have a larger percentage of
its land base receiving more levels of management
than it did in 1972. Determining allowable cut
levels decade by decade causes discrete jumps in
management requirements to occur with each new
allowable cut declaration. If the FY 83 budget is
maintained for the decade, the sustainable output
is estimated to be 184 MM bd. ft. per year.
Economic Efficiency of the Forest Management
Practices in the New Preferred Alternative (Alt. 9).
Commercial forest land in the Roseburg District is
managed under the principle of sustained yield.
The thrust of the district's forestry program is to
achieve economic and silvicultural efficiency and
environmental protection consistent with a high
level of annual or regular periodic output of
timber. The district has developed a forestry
program for its Management Framework Plan
(MFP). Among other goals, the selected forestry
program targets a package of management
practices which, ultimately, would be applied to
most acres on the district's commercial forest
land. Practices chosen by the district include tree
improvement through genetic selection, spacing
management (precommercial and commercial
thinning) and fertilization. This was the set of
practices which the district found to be technically
and environmentally feasible. This section
contrasts the economic payoff of the complement
of practices adopted in the Preferred Alternative
with other possible management combinations.
Research has established that, at the margin, each
of these practices yields a favorable ratio of
discounted dollar benefits to discounted dollar
costs when applied to forests which are managed
under sustained yield and have an abundance of
mature timber (allowable cut effect; see Beuter
and Handy 1974 and Hoyer 1975). Increasingly, as
the ratio of mature to immature timber declines,
Table B-1 Cost of Forest Management
in the New Preferred Alternative
(Alt. 9) and Original Proposed Action
(Alt. 4).
Major Program Area
Affecting Timber Harvest,
Reforestation and Growth
Transportation Systems'
Timber Management
Fire Management 2
Wildlife
Soil/Air/Water
Total
Annual Cost in
Thousands of Dollars
Alt. 4
Alt. 9
FY 1983
OPA
NPA
$1,696.6
$1,683.0
$1,134.9
7,174.8
7,120.9
5,176.7
529.4
525.1
183.3
128.0
128.0
110.0
100.0
100.0
94.0
$9,628.8 $9,557.0 $6,698.9
1 This category does not include funding for bridges, road and
aggregate production projects handled through the Federal
Highway Administration Funding for these projects is held at the
State Office. An estimated $500,000 is needed for these con-
struction projects.
2 Program areas directly related to reforestation and growth.
the significance of an allowable cut effect
dwindles. The district's target is a package of
practices which is economically efficient both now
and in future decades where there is no allowable
cut effect (as early as the fifth decade under the
Alternatives 1 through 5 and 9). The district
analyzed packages of practices by soil
expectation value per acre, where soil expectation
value is defined to be the value today of initiating
a management program on a nonstocked acre and
maintaining that program throughout the future.
Soil expectation values net discounted dollar
costs from discounted dollar returns. For
comparability, each complement of practices is
applied to average site conditions on the
Roseburg District (the Bureau's allowable cut
modeling is based on the average site conditions
in each sustained yield unit). Soil expectation
values are ranked using discount factors net of
inflation of 4 percent, 7.625 percent and 10
percent per year. The 4 percent rate is the factor
by which the U.S. Forest Service discounts future
returns and costs of forest management to
determine an equivalent value in today's dollars.
Their analysts argue that a 4 percent return net of
inflation is comparable to the yield on new long-
term investments in the private sector (Row et al.
1981). They also argue that the value of timber will
appreciate 1.65 percent per year faster than
general inflation for 50 years (Haynes et al. 1980).
Table B-2 summarizes the district's findings.
Arrayed are packages of practices which
maximize soil expectation value at various
discount rates and possible levels of price
appreciation.
Table B-2 Package of Practices
Which Maximizes the Soil Expectation
Value of Roseburg District Acres
Reforested 1984-1993 at Various
Discount Rates and Levels of Price
Appreciation
163
Budget and Revenue Implications of the New
Preferred Alternative (Alt. 9).
When measured in constant dollars, the
budget requirements of the Preferred Alternative
increase through the first four decades and then
steadily decline in the fifth through 14th decades
(Table B-3). The trend in revenues is tied to both
the long-term changes in the value of timber and
the type of timber BLM will offer in the future.
Today, in second-growth management, log values
and logging costs are sensitive to the average
diameter and volume harvested per acre (Sessions
1979). Each of the alternatives yields a diameter
size class to harvest acres to decade relationship.
Table B-3 reports prospective revenues by decade
for three possible combinations of base price and
appreciation in the value of timber (adjusted for
inflation). The table addresses questions raised by
members of the public in the EIS scoping process.
Some participants felt that the costs of the timber
management program in future decades may well
exceed revenues. The column in Table B-3 labeled
net return indicates that total revenues of the
Preferred Alternative will exceed total costs in
future decades at $260/M bd. ft. and where timber
values are increasing. The revenues would be the
amounts distributed to counties and the federal
treasury.
Discount
Rate
4%
Increase in
the Value of
Timber
1981 Price level
Plant Improved
of $260/M
Stock, Final
bd. ft
Harvest
1.65 Annual
Price Apprecia-
tion 1981-2030
1 65 Annual
Price Apprecia-
tion 1981
Forward
Plant Improved
Stock,
Precommercial
Thin,
Fertilize,
Final Harvest
Plant Improved
Stock, Precom-
mercial Thin.
Fertilize, Com-
mercial Thin,
Final Harvest
7.625%
Plant Improved
Stock, Final
Harvest
Plant Improved
Stock, Final
Harvest
Plant Improved
Stock, Precom-
mercial Thin.
Fertilize, Com-
mercial Thin,
Final Harvest
10%
Plant Improved
Stock, Final
Harvest
Plant Improved
Stock. Final
Harvest
Plant Improved
Stock, Precom-
mercial Thin,
Fertilize, Final
Harvest
164
Table B-3 Decadal Budget Requirements and Prospective Revenues of the
New Preferred Alternative (Alt. 9)
(millions of 1980 dollars)
Revenues @
Net Return
1.65%
@ 1 .65%
Annual
Annual
Increase
Increase
in Timber
in Timber
Budget Re-
Revenues at
Revenues at
Values
Net Return
Net Return
Values
scade
> quirements
$94/MBF 1
S260/MBF'
1980-2030
at $94/MBF at S260/MBF
1980-2030
1
95.60
232.18
642.20
723.84
136.58
546.60
628.24
2
87.04
221.78
613.43
820.26
134.74
526.39
733.21
3
101.19
204.50
565.65
897.33
103.31
464.46
796.14
4
109.06
173.75
480.60
929.37
64.69
371.54
820.31
5
94.80
72.87
201.55
699.83
-21.93
106.75
605.03
6
86.13
84.44
233.56
730.39
-1.69
147.43
644.25
7
90.01
70.55
195.14
719.18
-19.46
105.13
629.17
8
89.33
72.04
199.25
723.05
-17.29
109.93
633.72
9
84.99
68.44
189.32
698.44
-16.55
104.32
613.45
10
83.62
71.87
198.78
729.10
-11.76
115.15
645.47
11
83.39
82.54
228.31
789.51
-0.85
144.91
706.11
12
79.17
90.28
249.71
828.39
11.11
170.54
749.22
13
75.98
99.37
274.85
885.13
23.39
198.87
809.15
14
69.25
109.77
303.61
942.37
40.52
234.36
873.12
'Revenues per M bd. ft. are adjusted by the average diameter of harvest and the average volume per acre and based on current
experience and utilization standards.
165
Appendix C
Development of the Proposed
Action and Alternatives
Defining the proposed action is the last
phase of the planning process prior to preparation
of the EIS. Alternatives to the proposed action are
identified during the scoping phase of the
environmental analysis process. Each alternative
analyzed in this EIS contains a mix of variables
encompassing a range of choices for
decisionmakers as required by the CEQ
Regulations (40 CFR 1502.2 (2)).
In determination of a sustained yield allowable
cut, the primary variables are land classification,
acres allocated to timber production and
enhancement of growth assumed from specific
development practices or treatments. Following in
the order of occurrence are brief descriptions of
the inventories and processes employed to
determine the allowable cut level for the proposed
action and each alternative.
Land Classification and Inventory
Timber Production Capability
Classification
The Timber Production Capability
Classification (TPCC) is an intensive inventory
process initiated in 1972 to categorize all public
land administered by BLM in western Oregon
based upon the land's physical and biological
capacity to produce timber. TPCC was conducted
in accordance with Oregon Manual Supplement
5250.
The TPCC identified 402,000 acres of commercial
forest land which could be managed on a
sustained yield basis. Approximately 10,900 acres
of the commercial forest land were determined to
be incapable of undergoing harvest without
significant site degradation. These lands,
excluded from the timber production base, were
placed in this category when it was judged that
economically reasonable technology was not
available to mitigate such degradation. The
remainder of the SYUs' 21,900 acres was
determined to be non-forest or non-commercial
forest. If new data become available from intensive
on-site analysis or improvements occur in
technology, the classifications may be altered.
Operations Inventory
For BLM to carry out the timber management
program effectively, specific information as to the
location and current condition of the various
forest types within the land base must be available
to the managers. This is accomplished through
the Operations Inventory (Ol) in accordance with
procedures contained in the Operations Inventory
Handbook (STORMS).
The Ol is an intensive inventory providing forest
type maps which show the location and
classification of each homogeneous forest type
island. Ol record cards list acreage, silvicultural
needs and opportunities for application of forest
management practices on each type island.
Operations Inventory thus provides a basis for
establishing priorities for treatment based on
stand conditions and productivity.
1978 Forest Reinventory
A reinventory of commercial forest land in
the SYUs was completed in 1978 employing
procedures for extensive inventory jointly
developed by the USFS and BLM (USDA, FS
1976). The reinventory uses the same basic
inventory design as was used for determination of
the present allowable cut, but with further
refinement to include stratification of commercial
forest land based on information obtained from
the Ol and TPCC. Statistical analysis indicates the
sample mean volume per acre in the Roseburg
SYUs is within 8 percent of the true mean volume
per acre at one standard deviation.
The reinventory indicates a forest distribution as
displayed in Table C-1. Age classes range from
non-stocked, where reproduction has not been
established, to 500 years.
Table C-1 Existing Acres by Age
Class on All Forest Lands
Age
Age
Class
Acres
Class
Acres
Non-
stocked
7,403
210
5,849
1-5
26,740
220
5,649
10
40,853
230
25,085
20
36,568
250
12,291
30
13,852
260
4,348
40
5,973
270
1,504
50
9,065
280
2,294
60
11,319
290
1,301
70
8.959
300
13,799
80
10,931
310
6,882
90
11,741
320
2,294
100
13,282
340
2,294
110
16,879
350
2,294
120
20,008
380
4,588
130
3,595
390
2,294
140
3,595
400
2,294
150
10,545
410
2,294
160
5,616
470
2,294
170
6,197
490
742
180
21,947
500
6,882
190
8,305
200
3,592
Total
404,236
166
Other Resource Inventories
Inventories were conducted to identify and
categorize specific capability and potential of
resources other than timber. Recreation planners
applied the BLM's Recreation Information System,
an inventory approach for determining inherent
potential of the land to support various recreation
activities. Visual resource specialists inventoried
and classified the SYUs for visual and esthetic
considerations. A review and compilation of
known cultural resource data (Class I cultural
resource inventory) has been completed. Wildlife
biologists inventoried northern spotted owl and
bald eagle nest sites. Fisheries biologists
conducted surveys of streams within the district.
Botanical surveys for threatened and endangered
plants were initiated for the Roseburg District in
September 1978 and are updated yearly. A
district-wide soil inventory was completed by Wert
et al. 1977 (see References Cited).
Criteria for Selecting the Original
Proposed Action (Alternative 4)
The following criteria were used by the
District Manager in developing the Original
Proposed Action:
• Meet the long-term objective to attain a high
level of sustained yield timber production to
satisfy regional and national needs.
• Minimize soil loss caused by both management
activities and uncontrolled activities (e.g., off-road
vehicles).
• Contribute to the improvement or maintenance
of water quality in streams, rivers and municipal
watersheds, compared to current conditions.
• Minimize sediment reaching the stream and
water temperature changes that occur as a result
of management activities.
• Minimize impacts on air quality in residential
areas.
• Provide for developed and dispersed
recreational opportunities to meet demands
related to BLM-administered lands.
• Provide for maintaining the visual quality of the
forest landscape in areas of high sensitivity.
• Protect or improve and develop fish spawning,
rearing and migration habitat.
• Protect important wildlife habitat.
• Protect or enhance habitat of threatened or
endangered plant and animal species.
• Provide for scientific and educational study
through such programs as Research Natural
Areas.
• Allow minerals exploration and development
while protecting other resource values.
• Allow adequate land allocations for
communication sites, access development and
designation of right-of-way corridors while
protecting other resource values.
• Provide local economic stability through high
levels of local employment and personal earnings
which are dependent on raw materials, recreation
and other use opportunities available on lands
administered by BLM.
• Provide for a high level of contribution to local
public revenues from resources and activities
available on public lands.
• Demonstrate consistency with State planning
goals (Land Conservation and Development
Commission), acknowledged local comprehensive
plans, and officially approved local resource
related plans, programs and policies.
• Demonstrate consistency with other Federal
resource-related plans, programs, and policies.
(Provide coordinated approach to regional issues
and projects or proposals crossing administrative
lines.)
Land Use Allocation
During the development of the proposed land
use allocations, broad land use alternatives (MFP
Alternatives) were identified and reviewed by the
District to assess their effects. These MFP
alternatives were circulated for public review and
comment in 1981. Scoping (see Appendix B) of
the EIS led to the conclusion that four of these
land use allocation alternatives (some slightly
modified) were important enough to analyze in
depth. The resulting land use allocations by
alternative (Table C-2) were adapted from those
alternatives. Alternatives 1, 4, 6 and 8 of the draft
EIS were adapted from these alternatives.
Resource protection varies by alternative relative
to the mixture of land use allocations and
management features prescribed. Table C-3
shows acreage allocations, by resource, of the
MFP withdrawals and constrained timber
production bases. Table C-4 identifies proposed
management features applied during management
of the timber producing lands relative to the level
of protection provided by each alternative.
When final MFP timber management decisions are
made, they will form the management
prescriptions. Similarily, actions for other
resources, e.g., habitat management plans, will be
within the MFP guidelines.
167
Table C-2 Land Use Allocation Proposed for the EIS Alternatives (Acres)
No Planned Timber Harvest
Non-Commercial Forest Land
Non-Forest Lands
Fragile Site Withdrawals
Reforestation Withdrawals
MFP Withdrawals 2
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5'
Alt. 6
Alt. 7
Alt. 8
Alt. 9
Max. Tbr.
Emp. Tbr.
LoMHS
OPA
No Action
HD
No Herb.
Full Eco.
NPA
2,259
2.259
2,259
2,259
14,304
2,259
2,259
2,259
2,259
19,660
19,660
19,660
19,660
18,204
19,660
19,660
19,660
19,660
2,614
2,614
2,614
2,614
2,614
2,614
2,614
2,614
8,293
8,293
8,293
8,293
8,293
80,421
8,293
8,293
4,448
5,704
5,704
5,704
404
48,790
5,704
128,634
23,565
Sub-total
37,274
38,530
38,530
38,530
32,912
81,616 110,658 161,460
56,391
Planned Timber Harvest
Intensive Base
Constrained Base
VRM
Wildlife
386,622
360,580
333,319
333,319
377,098
222,357
261,191
331.637
3,682
2,646
2,646
5,812
31,345
2,646
49,376
2,658
21,104
49,401
49,401
8,074
88,579
49,401
213,060
33,210
Sub-total
Total SYUs Acres
386,622 385,366 385,366 385,366 390,984 342,281 313,238 262,436 367,505
423,896 423,896 423.896 423,896 423,896 423,896 423,896 423,896 423,896
1 Land use allocations for Alternative 5 (No Action) resulted from the land classification instructions used in the 1970 planning
process. For example, fragile sites and reforestation withdrawal are contained in the non-commercial forest land category.
2 These are commercial forest lands withdrawn from the timber production base for other resourc considerations. See Table C-3
for the identified resource and acres allocated.
Table C-3 Acreage Allocation by Resource
Alt. 1
Max.Tbr.
Alt. 2
Emp. Tbr.
Alt. 3
LoMHS
Alt. 4
OPA
Alt. 5
No Action
Alt. 6
HD
Alt. 7
No Herb.
Alt. 8
Full Eco.
Alt. 9
NPA
611
508
502
611
508
1,185
611
508
1,185
611
508
1,185
404
570
508
2,773
611
508
1,185
570
508
4,615
611
508
1,185
2,912
2,912
640
2,912
640
2,912
640
2.769
1,280
21,422
26,383
2,912
640
2,560
40,098
90,707
2,699
640
18.332
Resource Considerations in
Acres *
MFP WITHDRAWALS
Botanical
Cultural
Recreation 1
Wildlife:
Bald Eagle
Golden Eagles & Raptors
Old Growth Blocks
Riparian Areas
VRM II
CONSTRAINED TIMBER PRODUCTION
BASE
Visual Resource Management
Wildlife:
Bald Eagle
Northern Spotted Owl
Old Growth Blocks
80 Acre Blocks
Osprey
Riparian Areas
"Acres are not additive due to overlap.
' Includes developed sites, recreation facilities, research natural areas, outstanding natural areas and in Alternatives 6 and 8 sites
pending suitability studies.
8,383
8,383
8,383
5.812
45,703
8,383
90.703
8.383
8.769
19,826
19,826
27,407
19,826
54,940
20.321
14,700
14,700
14,700
16,780
10,582
10,582
67,727
10,582
102,466
11,370
3,445
3,445
3,445
5,273
3,445
10,430
3.058
18,332
18,332
18,332
8,074
18,332
168
Table C-4 Management Features
Resource Feature
WILDLIFE
AIM
All. 2
Alt. 3
Alt.4
Alt. 5
Alt. 6
Alt. 7
Alt. 8
Alt. 9
Max. Tbr.
Emp. Tbr.
Lo MHS
OPA
No Action
HD
No Herb.
Full Eco.
NPA
Riparian Zones
No timber
No restriction
Same as »2
Same as #2
No harvest
No harvest
Same as »2
Complete
No harvest
harvest
on 1st and 2nd
restriction on
restriction on
protection on
restriction on
restrictions
order streams.
1st and 2nd
1st and 2nd
all stream
1st and 2nd
Approximately
order streams
order streams;
orders, totaling
order streams.
18.300 acres
An estimated
an estimated
approximately
an estimated
along 3rd order
8,070 acres
26,400 acres
90.700 acres.
18.300 acres
and larger
along 3rd order
along 3rd order
along 3rd order
streams would
and larger
and larger
and larger
be managed
streams would
streams would
streams would
under modified
receive
receive
receive
area control.
protection.
complete
complete
Harvest is
protection
protection.
expected to
occur on an
estimated 6%
of this area, of
which 11%
would be
clearcut.
Snags (#/acre)
Northern
Spotted Owls
Managed for
(pairs)
None on 6/acre in
intensive modified area
timber base control 3/ac.
6/acre on other on remainder
forest lands
Same as #3
Non on
intensive base
3/ac. on other
forest land
2/acre on 25% Same as #3
of intensive
outside of old
growth areas
3/ac on old
growth and
other land with
no planned
timber harvest.
25
3/acre on 35% Same as #3
of land base
outside of old
growth areas.
3/acre on old
growth and
other lands
with no
planned timber
harvest.
55
19
Spacing
Between
Clearcuts (year)
3-5
3-5
5 year on
intensive base
variable in
modified area
control
Same as #3
3-5
10
Same as #3
Same as #3
Modified Area
Control (acres)
24,800
52.050
52,050
52.050
35.868
RECREATION
Potential
Recreation
Sites (#)
3
12
12
12
8
12
8
12
Natural Areas
(potential) (#)
(designated) (#)
2
6
2
6
2
6
2
2
6
2
6
2
6
2
6
2
Areas of Critical
Environmental
Concern
(number/acres)
4/600
4/2.100
4/2.100
4/2,100
8/3,100
4/2.100
8/3.100
4/2,100
Visual Resource
Management
Classes (acres)
I
II
III
IV
30
2.400
400
421.170
30
9.300
13.600
401.070
30
9.300
13,600
401,070
30
9.300
13.600
401.070
30
1.100
3,000
419.870
30
26,600
22,400
374.970
30
9.300
13.600
401.070
30
75,700
22,900
325.370
30
30
13.600
401,070
169
Modified Area Control
Modified area control is a process for
managing a given number of acres under a special
timber harvest regime. In the Roseburg District,
52,047 acres are proposed to be managed under
the modified area control concept for Alternatives
3, 4 and 7, 35,868 acres for Alternative 9 and
24,786 acres for Alternative 2. Harvest methods
and volumes will vary, ranging from clearcut to
individual tree selection, depending on the
particular resource involved, the degree of
protection necessary and the silvicultural system
used.
Although in practice not every area would be cut,
for purposes of calculating allowable cut yields, it
was assumed the entire acreage would be
managed oh a 250 year harvest age. The volume
to be harvested during the first decade under this
concept was calculated manually, and the result
was tested using SIMIX to ensure sustainability.
Approximately 9 MM bd. ft. would be scheduled
for harvest from these areas each year, except in
Alternative 2, where modified area control harvest
would be approximately 4 MM bd. ft, and
Alternative 9, where harvest would be
approximately 6 MM bd. ft. In actual practices, the
volume generated would probably be
concentrated during the last half of the decade,
rather than occurring as a constant annual flow.
This is caused by the necessity to complete
detailed habitat and visual management plans on a
number of these areas prior to scheduling timber
harvests.
Forest land acres and age class distribution were
determined individually for the allocations to
benefit each resource. A listing of lands proposed
for modified area control was developed as
follows:
Resource Allocation
Mid-age and
Old Growth
Riparian
VRM II
TOTAL
Comi
mercial Forest Land
Acres 1
Alt. 2
Alts. 3,
4& 7
Alt. 9
2,772
18,332
3,682
32,882
16,519
2,646
33,210
2,658
24,786 52,047
35,868
' Overlaps between resource allocations were eliminated.
Mid-age and old-growth is located in loosely
arranged corridors. Ties with corridors in
adjoining BLM districts are incorporated. These
components also include functioning old growth
systems distributed by seed zone and elevation in
order to safeguard long term timber productivity
(see Serai Stage Distribution Concept, Appendix
A).
That portion of the allocated mid-age and old
growth which exists as 80-acre blocks would be
managed to maintain, as a minimum, 70 percent of
these blocks in the 120+ age class. Normally,
management would be to harvest the entire
selected block within a decade to create an even-
age stand, thereby attaining desired wildlife values
in the future.
Osprey and heron habitat would be managed with
seasonal harvest limitations to avoid disturbance
of nesting pairs. When osprey and heron habitat
overlaps visual protection areas, timber harvest
would be managed in conjunction with VRM plans
to maintain visual quality. Harvest in VRM II zones
would be conducted according to the sequential
settings delineated in the visual resource
management plans. All visual plans are scheduled
for completion by 1989.
Modified Area Control on Riparian
Areas
For Alternatives 2, 3, 4 and 7 approximately
18,300 acres of riparian areas along third order
and greater streams would be managed in
vegetative buffers averaging 200 feet wide. This
includes the actual riparian habitat (10,650 acres)
shown in Chapter 2 plus additional transitional
vegetation (7,650 acres). These areas would be
managed to provide riparian values, including
habitat structure important to cavity dwellers and
other species, to maintain shade and woody
structure important to fish habitat and to protect
stream bank stability for water quality and
temperature control.
Prior to timber management activities in these
areas, site specific interdisciplinary plans would
be completed to delineate riparian values as well
as appropriate harvest levels and project design
features.
In riparian areas, clearcuts would be permitted for
road crossings, yarding corridors and harvest of
small isolated parcels. This would permit access
to the majority of the district land base, while
minimizing impacts to a small portion of the
riparian area. According to the sample 5-year
timber sale plan, approximately 12 acres of
riparian vegetation would be clearcut each year.
In addition, the sample 5-year timber sale plan
includes approximately 96 acres that would be
partial cut each year. In partial cut areas,
silvicultural systems ranging from individual tree
selection to group selection or shelterwood would
be used.
The remaining areas of riparian vegetation are not
planned for entry during the first decade.
Management practices which would be applied to
riparian areas (including streamside buffers)
include directional falling of timber away from
170
streams, no machinery operation in streams
(except for road construction, e.g., bridges and
culverts) and full suspension yarding across
riparian management areas. No burning would be
conducted in the riparian management areas.
As information and greater understanding
regarding the management of these areas are
gained throughout the decade, necessary
revisions would be incorporated into the next
planning cycle.
Allowable Cut Computation
Forest Simulation Model
A computerized forest simulation model
(SIMIX) is used to determine the highest
sustainable allowable cut for each alternative.
SIMIX calculates the allowable cut associated with
the stated forest management plan. It can
maximize an even-flow level of cut for some
specific management regime, or a series of cut
levels may be specified for as many as the first 10
decades followed by an even-flow level for the
remainder of the projected period (40 decades).
This lengthy projection period is not an attempt at
a 400-year plan. It is used only to assure that the
condition of no planned reduction in allowable cut
can be met.
The clearcut option of SIMIX was utilized since
clearcut is the predominant harvest method in all
alternatives. For accuracy in measuring lumber
and plywood production, the allowable cut is
computed and projected into the future on the
basis of cubic feet.
SIMIX computes the harvest level based on
present inventory and projected growth resulting
from the application of certain management
practices (mortality salvage, precommercial and
commercial thinning, commercial thinning only,
forest genetics and final harvest cuts). Another
treatment, fertilization, is included in conjunction
with one or more of the above treatments. SIMIX
must be told what treatments, when and the
number of acres, to be treated. No rotation age is
set; instead, a minimum cutting age constraint is
specified. SIMIX is not designed to handle
economic values or costs, and it does not seek out
alternative schedules or strategies.
The model, designed for forests under an even-
aged system of management, produces output
data by decades for each age and treatment class
and summarizes them numerically and
graphically. These data include level of growing
stock, annual growth, acreage by silvicultural
practices and volume by harvesting practice.
Consequently, it permits alternative plans to be
evaluated on the basis of their respective
production levels and fiscal requirements and
serves as a basis for programming personnel and
funds for the alternative selected. In effect, a
management plan is developed that schedules the
production from commercial thinning, mortality
salvage and final harvest operations and also the
acreages for such treatments as reforestation and
precommercial thinning. The model is geared to
the proposed policies but is flexible to the extent
that other regulatory policies can be applied in its
use.
The Allowable Cut Effect (ACE)
A forest that is composed primarily of
old-growth timber and recently cut-over stands
exhibits a relatively low average annual growth.
This results from slow or negative growth of the
old stands and the fact that growth is not
measurable (in end-product terms) in the young
stands until they reach 20 or 30 years of age. Such
a forest is in transition from an unmanaged to a
managed or regulated state. In the classical sense,
the regulated state is achieved when average
annual harvest and growth are in equilibrium. At
this point, maximum yield on a sustainable basis is
reached. To compute an allowable cut on a forest
in the transition state using this criteria would be
extremely conservative and greatly lengthen the
time until the regulated state was achieved. The
BLM uses an alternative approach which is to
project growth into the future based upon
assumptions about management levels and to
utilize excess harvest age timber to bridge the
time gap until the ultimate growth level is
achieved. This process of taking credit now for
future growth increases expected to result from
management has been termed the "Allowable Cut
Effect" (ACE).
Figure C-1 illustrates this process in the context of
conditions found in the SYUs, before land use
allocations were made to other resource activities.
This forest is in the early to middle transition stage
and, as the recent inventory found, has a relatively
low average annual growth rate. An initial
computation was made that assumed no intensive
management practices were performed. Under
this scheme, stands were projected to grow in a
fashion similar to normal unmanaged forests. The
lower growth curve in Figure C-1 shows the
average annual growth path projected from these
assumptions. When tested on the allowable cut
model, it was determined that sufficient harvest
age timber was available to bridge the gap until a
regulated state was achieved.
Next, a high level of management was assumed.
Practices (see Chapter 1, Forest Management
Treatments and Design Elements) such as genetic
improvement, precommercial and commercial
thinning, fertilization and mortality salvage were
used in projecting yield functions. The basis for
most of these projections was the DFIT model.
The higher growth curve in Figure C-1 shows the
average annual growth path resulting from the
intensive management assumptions. When tested
171
on the allowable cut model, it was determined that
there was only enough harvest age timber
available to take credit for a portion of the
expected future growth increases. For full ACE
credit to apply, there must be enough harvestable
timber to bridge the previously mentioned time
gap. Since this was not the case in the Roseburg
SYUs, the allowable cut effect applied was limited
to about 53 percent of the projected potential
allowable cut effect. To set a cut level higher than
the "actual" would cause a drop in future cut
levels, a violation of Bureau policy. The foregoing
narrative is supplemented by Figure C-2 which
portrays both data source and information flow
sequence for the allowable cut determination
process.
FIGURE C-l
ALLOWABLE CUT EFFECT
ALLOWABLE
CUT
POTENTIAL HARVEST
WITH INTENSIVE MANAGEMENT
EFFECT
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172
Figure C-2
Bureau Planning System
All Resource Data
Allowable Cut Planning System
Forestry Data
Policy, Guidance,
Socio-economic Data
Resource Analysis
Existing Situation
• Present forest condition
Summary Data
Opportunities
Initial decade treated acres by intensive management practice
Ultimate acreage to undergo Intensive management
Yields for each intensive management practice
1
Management Framework Plans
• Select forest management practices which meet the test
of environmental and economic feasibility
Forest Management Policy
minimum harvest age
District Inputs
i— Forest Reinventory
Timber Production
Capability Classification
Regeneration Lag
Emperic and Non-treated
Yield Curves (DFIT)
Final Harvest Acres
by Cutting Practice
Young Growth Management Committee Report
Feasible and unfeasible intensive management practices
Operations Inventory
Forest Stand Development Opportunities
Land Use Allocation - Acres
Decisions resolving conflicting opportunities
• Based on tests of various multiple use constraints
Environmental Impact Statement
Draft and final documents analyze impacts of proposed
action and other alternatives
Decision
Allowable cut declared, management framework plan
implemented
Simix Model
Inputs:
• Acreage and age class distribution in allowable cut land base'
• Minimum harvest age'
• Acreages to be treated during initial decade by intensive management'
• Ultimate acreage to undergo intensive management'
• Empirical and non-treated yields'
• Yields for each intensive management practice'
• Regeneration lag
• Acreage removed from the timber production base by decade due to roading
• Acreage constrained because of multiple use consideration
• Acreage foregone because of multiple use consideration
Outputs:
Decadal printout covering 40 decades contains
• Even flow volume
• Age class distribution
• Acreages for PCT
• Acreages and volumes for commercial thinning, morlality salvage and final
harvest
• Growth and standing volumes
'Primary determinants of the degree of allowable cut effect
Appendix D Wildlife
173
Conifer Habitat
Other Habitat
Key
Resident Habitat
P=Permanent U=Uses
S=Summer 0=Optimum
W=Winter
M=Migratory
Relative Abundance
A=Abundant
C=Common
U=Uncommon
R=Rare
Mammals
Virginia Opossum (Didelphis virginiana)
Vagrant Shrew (Sorex vagrans)
Dusky Shrew (Sorex obscurus)
Pacific Shrew (Sorex pacificus)
Virginia Opossum (Didelphis virginiana)
Vagrant Shrew
Water Shrew (Sorex palustris)
Pacific Water Shrew (Sorex bendirii)
Trowbridge's Shrew (Sorex trowbridgii)
Shrew-mole (Neurotrichus gibbsii)
Townsend's Mole (Scapanus townsendii)
Coast Mole (Scapanus orarius)
Little Brown Myotis (Myotis lucifugus)
Yuma Myotis (Myotis yumanensis)
Long-eared Myotis (Myotis evotis)
Fringed Myotis (Myotis thysanodes)
Long-legged Myotis (Myotis volans)
California Myotis (Myotis californicus)
Silver-haired Bat (Lasionycteris noctivagans)
Big Brown Bat (Eptesicus fuscus)
Hoary Bat (Lasiurus cinereus)
Townsend's Big-eared Bat (Plecotus townsendii)
Pallid Bat (Antrozous pallidus)
Brazilian Free-Tailed Bat (Tadarida brasiliensis)
Pika (Ochotona princeps)
Brush Rabbit (Sylvilagus bachmani)
Snowshoe Hare (Lepus americanus)
Black-tailed Jackrabbit (Lepus californicus)
Mountain Beaver (Aplodentia rufa)
Townsend's Chipmunk (Eutamias townsendii)
California Ground Squirrel (Spermophilus beecheyi)
Western Gray Squirrel (Sciurus griseus)
Douglas' Squirrel (Tamiasciurus douglasii)
Northern Flying Squirrel (Glaucomys sabrinus)
Botta's Pocket Gopher (Thomomys bottae)
Western Pocket Gopher (Thomomys mazama)
Beaver (Castor canadensis)
Deer Mouse (Peromyscus maniculatus)
Dusky-footed Woodrat (Neotoma fuscipes)
Bushy-tailed Woodrat (Neotoma cinerea)
Western Red-backed Vole (Clethrionomys occidentalis)
White-footed Vole (Phenacomys albipes)
Red Tree Vole (Phenacomys longicaudus)
California Vole (Microtus californicus)
Townsend's Vole (Microtus townsendii)
Long-tailed Vole (Microtus longicaudus)
Creeping Vole (Microtus oregoni)
Muskrat (Ondatra zibethicus)
Norway Rat (Rattus norvegicus)
House Mouse (Mus musculus)
Pacific Jumping Mouse (Zapus trinotatus)
Porcupine (Erethizon dorsatum)
Nutria (Myocaster coypus)
Coyote (Canis latrans)
Red Fox (Vulpes vulpes)
Gray Fox (Urocyon cinereoargenteus)
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174
Appendix D Wildlife (continued)
Conifer Habitat
Key
Resident Habitat
P=Permanent U=Uses
S=Summer 0=Optimum
W^Winter
M-Migratory
Relative Abundance
A=Abundant
OCommon
U^Uncommon
R=Rare
Black Bear (Ursus americanus)
Ringtail (Bassariscus astutus)
Raccoon (Procyon lotor)
Marten (Martes americana)
Fisher (Martes pennanti)
Ermine (Mustela erminea)
Long-tailed Weasel (Mustela frenata)
Mink (Mustela vison)
Western Spotted Skunk (Spilogale gracilis)
Striped Skunk (Mephitis mephitis)
River Otter (Lutra canadensis)
Mountain Lion (Felis concolor)
Bobcat (Felis rufus)
Roosevelt Elk (Cervus elaphus rooseveltii)
Columbian Black-tailed Deer
Odocoileus hemionus columbianus)
Columbian White-tailed Deer
(Odocoileus Virginians leucurus)
Birds
Common Loon (Gavia immer)
Eared Grebe (Podiceps nigricollis)
Western Grebe (Aechmophorus occidentalis)
Pied-billed Grebe (Podilymbus podiceps)
Double-crested Cormorant (Phalacrocorax auritus)
Great Blue Heron (Ardea herodias)
Green Heron (Butorides striatus)
Great Egret (Casmerodius albus)
Black-crowned Night Heron (Nycticorax nycticorax)
American Bittern (Botarus lentiginosus)
Whistling Swan (Olor columbianus)
Canada Goose (Branta canadensis)
White-fronted Goose (Anser albifrons)
Snow Goose (Chen caerulescens)
Mallard (Anas platyrhynchos)
Gadwall (Anas strepera)
Pintail (Anas acuta)
Green-winged Teal (Anas crecca)
Blue-winged Teal (Anas discors)
Cinnamon Teal (Anas cyanoptera)
American Wigeon (Anas americana)
Northern Shoveler (Anis clypeata)
Wood Duck (Aix sponsa)
Redhead (Aythya americana)
Ring-necked Duck (Aythya collaris)
Canvasback (Aythya valisineria)
Greater Scaup (Aythya marila)
Lesser Scaup(Aythya affinis)
Common Goldeneye (Bucephala clangula)
Bufflehead (Bucephala albeola)
Ruddy Duck (Oxyura jamaicensis)
Hooded Merganser (Lophodytes cucullatus)
Other Habitat
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Appendix D Wildlife (continued)
175
Conifer Habitat
Other Habitat
Key
Resident Habitat
P=Permanent U^Uses
S=Summer OOptimum
W=Winter
M=Migratory
Relative Abundance
A-- Abundant
OCommon
U=Uncommon
R=Rare
Common Merganser (Mergus Merganser)
Red-breasted Merganser (Mergus serrator)
Turkey Vulture (Cathartes aura)
Northern Goshawk (Accipiter gentilis)
Sharp-shinned Hawk (Accipiter striatus)
Cooper's Hawk (Accipiter cooperi)
Red-tailed Hawk (Buteo jamaicensis)
Rough-legged Hawk (Buteo lagopus)
Golden Eagle (Aquila chrysaetos)
Bald Eagle (Haliaeetus leucocephalus)
Northern Harrier (Circus cyaneus)
Osprey (Pandion haliaetus)
Prairie Falcon (Falco mexicanus)
Merlin (Falco columbarius)
American Kestrel (Falco sparverius)
Blue Grouse (Dendragapus obscurus)
Ruffed Grouse (Bonasa umbellus)
California Quail (Lophortyx californicus)
Mountain Quail (Oreortyx pictus)
Ring-necked Pheasant (Phasianus colchicus)
Virginia Rail (Rallus limicola)
Sora (Porzana Carolina)
American Coot (Fulica americana)
Semi-palmated Plover (Calidris pusilla)
Killdeer (Charadrius vociferus)
Common Snipe (Capella gallinago)
Spotted Sandpiper (Actitis macularia)
Solitary Sandpiper (Tringa solitaria)
Greater Yellowlegs (Tringa melanoleucus)
Lesser Yellowlegs (Tringa flavipes)
Least Sandpiper (Calidris minutilla)
Long-billed Dowitcher (Limnodromus scolopaceus)
Dunlin (Calidris alpina)
Western Sandpiper (Calidris mauri)
Short-billed Dowitcher (Limnodromus griseus)
Northern Phalarope (Lobipes lobatus)
Glaucous-winged Gull (Larus glaucescens)
Western Gull (Larus occidentalis)
Herring Gull (Larus argentatus)
California Gull (Larus californicus)
Ring-billed Gull (Larus delawarensis)
Band-tailed Pigeon (Columba fasciata)
Rock Dove (Columba livia)
Mourning Dove (Zengida macroura)
Barn Owl (Tyto alba)
Screech Owl (Otus asio)
Great Horned Owl (Bubo virginianus)
Snowy Owl (Nyctea scandiaca)
Pygmy Owl (Glaucidium gnoma)
Northern Spotted Owl (Strix occidentalis)
Short-eared Owl (Asio flammeus)
Saw-whet Owl (Aegolius acadicus)
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176
Appendix D Wildlife (continued)
Conifer Habitat
Other Habitat
Key
Resident Habitat
P=Permanent LNUses
S=Summer 0=Optimum
W=Winter
M=Migratory
Relative Abundance
A-Abundant
C=Common
U-Uncommon
R=Rare
Common Nighthawk (Chordeiles minor)
Vaux's Swift (Chaetura vauxi)
Anna's Hummingbird (Calypte anna)
Rufous Hummingbird (Selasphorus rufus)
Belted Kingfisher (Megaceryle alcyon)
Common Flicker (Colaptes auratus)
Pileated Woodpecker (Dryocopus pileatus)
Acorn Woodpecker (Melanerpes formicivorus)
Lewis Woodpecker (Melanerpes lewis)
Yellow-bellied Sapsucker (Sphyrapicus varius)
Hairy Woodpecker (Picoides villosus)
Downy Woodpecker (Picoides pubescens)
Western Kingbird (Tyrannus verticalis)
Ash-throated Flycatcher (Myiarchus cinerascens)
Willow Flycatcher (Empidonax traillii)
Hammond's Flycatcher (Empidonax hammondii)
Dusky Flycatcher (Empidonax oberholseri)
Western Flycatcher (Empidonax difficilis)
Western Wood Pewee (Contopus sordidulus)
Olive-sided Flycatcher (Nuttallornis borealis)
Violet-green Swallow (Tachycineta thalassina)
Tree Swallow (Iridoprocne bicolor)
Bank Swallow (Riparia riparia)
Rough-winged Swallow (Stelgidopteryx ruficollis)
Barn Swallow (Hirundo rustica)
Cliff Swallow (Petrochelidon pyrrhonota)
Purple Martin (Progne subis)
Gray Jay (Perisoreus canadensis)
Steller's Jay (Cyanocitta stelleri)
Scrub Jay (Aphelocoma coerulescens)
Northern Raven (Corvus corax)
American Crow (Corvus brachyrhynchos)
Black-capped Chickadee (Parus atricapillus)
Mountain Chickadee (Parus gambeli)
Chestnut-backed Chickadee (Parus rufescens)
Bushtit (Psaltriparus minimus)
White-breasted Nuthatch (Sitta carolinensis)
Red-breasted Nuthatch (Sitta canadensis)
Pygmy Nuthatch (Sitla pygmea)
Brown Creeper (Certhia familaris)
Wrentit (Chamaea fasciata)
Dipper (Cinclus mexicanus)
House Wren (Troglodytes aedon)
Winter Wren (Troglodytes trogladytes)
Bewick's Wren (Thryomanes bewickii)
Long-billed Marsh Wren (Cistothorus palustris)
American Robin (Turdus migratorius)
Varied Thrush (Ixoreus naevius)
Hermit Thrush (Catharus guttata)
Swainson's Thrush (Catharus ustulata)
Western Bluebird (Sialia mexicana)
Townsend's Solitaire (Myadestes townsendi)
Golden-crowned Kinglet (Regulus satrapa)
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Appendix D Wildlife (continued)
177
Conifer Habitat
Other Habitat
Key
Resident Habitat
P^Permanent U=Uses
S=Summer 0=Optimum
W=Winter
M=Migratory
Relative Abundance
A-Abundant
OCommon
U=Uncommon
R=Rare
Ruby-crowned Kinglet (Regulus calendula)
Water Pipit (Anthus spinoletta)
Bohemian Waxwing (Bombycilla garrulus)
Cedar Waxwing (Bombycilla cedrorum)
Northern Shrike (Lanius excubitor)
Starling (Sturnus vulgaris)
Hutton's Vireo (Vireo huttoni)
Solitary Vireo (Vireo solitarius)
Warbling Vireo (Vireo gilvus)
Orange-crowned Warbler (Vermivora celata)
Nashville Warbler (Vermivora ruficapilla)
Yellow Warbler (Dendroica petechia)
Yellow-rumped Warbler (Dendroica coronata)
Black-throated Gray Warbler (Dendroica nigrescens)
Townsend's Warbler (Dendroica townsendi)
Hermit Warbler (Dendroica occidentalis)
MacGillivray's Warbler (Oporornis tolmiei)
Yellowthroat (Geothlypis trichas)
Yellow-breasted Chat (Icteria virens)
Wilson's Warbler (Wilsonia pusilla)
House Sparrow (Passer domesticus)
Western Meadowlark (Sturnella neglecta)
Yellow-headed Blackbird
(Xanthocephalus xanthocephalus)
Red-winged Blackbird (Agelaius phoeniceus)
Northern Oriole (Icterus galbula)
Brewer's Blackbird (Euphagus cyanocephalus)
Brown-headed Cowbird (Molothrus ater)
Western Tanager (Piranga ludoviciana)
Black-headed Grosbeak
(Pheucticus melanocephalus)
Lazuli Bunting (Passerina amoena)
Evening Grosbeak (Hesperiphona vespertina)
Purple Finch (Carpodacus purpureus)
House Finch (Carpodacus mexicanus)
Pine Siskin(Carduelis pinus)
American Goldfinch (Carduelis tristis)
Lesser Goldfinch (Carduelis psaltria)
Red Crossbill (Loxia curvirostra)
Rufous-sided Towhee (Pipilo erythrophthalmus)
Savannah Sparrow (Passerculus sandwichensis)
Vesper Sparrow (Pooecetes gramineus)
Dark-eyed Junco (Junco hyemalis)
Chipping Sparrow (Spizella passerina)
White-crowned Sparrow (Zonotrichia leucophrys)
Golden-crowned Sparrow (Zonetrichia atricapilla)
Fox Sparrow (Passerella iliaca)
Lincoln's Sparrow (Melospiza lincolnii)
Song Sparrow (Melospiza melodia)
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Appendix D Wildlife (continued)
Key
Conifer Habitat
Other Habitat
Resident
P^Permanent
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R^Rare
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Western Pond Turtle (Clemmys marmorata)
Western Fence Lizard (Sceloporus occidentalis)
Western Skink (Eumeces skiltonianus)
Southern Alligator Lizard
(Gerrhonotus multicarinatus)
Northern Alligator Lizard (Gerrhonotus coeruleus)
Rubber Boa (Charina bottae)
Ringneck Snake (Diadophis punctatus)
Sharp-tailed Snake (Contia tenuis)
Western Yellow-bellied Racer (Coluber constrictor)
Pacific Gopher Snake (Pituophis melanoleucus)
Common Kingsnake (Lampropeltis getulus)
California Mountain Kingsnake (Lampropeltis zonata) P
Common Garter Snake (Thamnophis sirtalis)
Western Terrestrial Garter Snake
(Thamnophis elegans)
Western Aquatic Garter Snake (Thamnophis couchi)
Northwestern Garter Snake (Thamnophis ordinoides)
Western Rattlesnake (Crotalus molossus)
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Northwestern Salamander (Ambystoma gracile)
Long-toed Salamander (Ambystoma macrodactylum)
Pacific Giant Salamander (Dicamptodon ensatus)
Olympic Salamander (Rhyacotriton olympicus)
Rough-skinned Newt (Taricha granulosa)
Dunn's Salamander (Plethodon dunni)
Western Red-backed Salamander
(Plethodon vehiculum)
Oregon Salamander (Ensatina eschscholtzi)
Clouded Salamander (Aneides ferreus)
Tailed Frog (Ascaphus truei)
Western Toad (Bufo boreas)
Pacific Tree Frog (Hyla regilla)
Red-legged Frog (Rana aurora)
Yellow-legged Frog (Rana boylei)
Bullfrog (Rana catesbeiana)
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Appendix E
179
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Glossary of Terms
Absorb - To be held within the structure of a
substance.
Acre-foot - The volume of water that will cover
one acre to a depth of one foot.
Adsorb - To be held on the surface of a substance.
Allowable Cut - The amount of forest products
that may be harvested annually or periodically
from a specified area over a stated period in
accordance with the objectives of management.
Allowable Cut Effect (ACE) - The immediate
increase in today's allowable cut which is justified
by expected future increases in yields due to
present or proposed management treatments.
Allowable Cut Determination Process - A process
which deals with the steps involved in the
development and evaluation of alternative levels of
timber production for the purpose of establishing
an allowable cut.
Ambient - Surrounding, on all sides; for air, refers
to any unconfined portion of the atmosphere.
Anadromous Fish - Fish which migrate from the
sea to breed in fresh water. Their offspring return
to the sea.
Aquifer - A geologic formation or structure that
transmits water in sufficient quantity to supply the
needs for a water development; usually saturated
sands, gravel, fractures, and cavernous and
vesicular rock. The term water-bearing is
sometimes used synonymously with aquifer when
a stratum furnishes water for a specific use.
Archeological Resources - All evidences of past
human occupations other than historical
documents, which can be used to reconstruct the
lifeways of past peoples. These include sites,
artifacts, environmental data and all other relevant
information.
Area of Critical Environmental Concern (ACEC) -
An area within the public lands where special
management attention is required (when such
areas are developed or used, or where no
development is required) to protect and prevent
irreparable damage to important historic, cultural,
or scenic values, fish and wildlife resources or
other natural systems or processes, or to protect
life and safety from natural hazards (FLPMA Sec.
103(a)).
Aspect - The direction a slope faces.
Average Employment - The sum of number of
employees, reported monthly, divided by twelve;
because employment is reported for all employees
working during any one month, it is a modest
over-estimate of full-time equivalent employment.
190
Background - That portion of an area being
viewed beyond the foreground-middleground (3 to
5) miles to a maximum of about 15 miles from a
travel route, use area, or other observer position.
Background Levels - Amounts of pollutants
present from natural sources and from human
disturbances which have reached equilibrium.
Basal Area - The area of the cross-section of a
tree stem near its base, generally at breast height
and inclusive of bark. It is usually expressed as
square feet per acre.
Bedload - The sediment that moves by sliding,
rolling or bounding, on or very near, the
streambed.
Biome - The largest land community unit (plant
and animal) which is convenient to recognize.
Board Foot - A unit of solid wood, 1-foot square
and 1-inch thick.
British Thermal Unit (Btu) - A unit of heat equal to
252 calories; quantity of heat needed to raise the
temperature of one pound of water from 62 F. to
63 F.
Broadcast Burning - Intentional burning in which
fire is intended to spread over all of a specific
area. It may or may not qualify as prescribed
burning.
Bucking - Cutting trees into log lengths.
Buffer Strip - A protective area adjacent to an area
requiring special attention or protection.
Bureau Planning System - A process used in the
BLM to establish land use allocations, constraints,
and objectives for various categories of public
land use.
Characteristic Landscape - The established
landscape within a physiographic province. The
term does not necessarily mean "naturalistic
character." It could refer to farm lands, timber
lands or other landscapes which exhibit both
physiographic and land use similarities.
Clearcutting - A method of timber harvesting in
which all trees, merchantable or unmerchantable,
are cut from an area.
Commercial Forest Land - Forest land that is now
producing or is capable of producing at least 20
cubic feet per acre per year of commercial
coniferous tree species.
Commercial Thinning - Partial cuttings made in
merchantable stands (40-70 years old) in order to
stimulate the growth of remaining trees and
increase total yield from the stand.
Community Income Effect - The sum of direct and
indirect personal income generated by a change,
e.g., timber harvest. Indirect personal income
results from economic activity stimulated in other
local enterprises by purchase of goods and
services, primarily of a support nature.
Constrained Timber Production Base - Base
acreage managed for timber production at a lesser
intensity in consideration for other resource
management objectives, e.g., minimum harvest
ages of 60 to 350 years for wildlife habitat (see
Intensive Timber Production Base).
Contrast - The effect of a striking difference in the
form, line, color or texture of the landscape
features within the area being viewed.
Contrast Rating System - A method of
determining the extent of visual impact for an
existing or proposed activity that will modify any
landscape feature (land and water form,
vegetation and structures).
Coos Bay Wagon Road (CBWR) Lands - Public
lands granted to the Southern Oregon Company
and subsequently reconveyed to the United
States.
Critical Habitat - That habitat considered by the
Secretary of the Interior to be necessary to the
normal needs or survival and recovery of listed
Threatened or Endangered Species. It may also
include habitat not currently occupied into which
a listed species could expand.
Cull - A tree or log which is rejected because it
does not meet certain specifications.
Cultural Resources - Those fragile and
nonrenewable remains of human activity,
occupation, or endeavor, reflected in districts,
sites, structures, buildings, objects, artifacts,
ruins, works of art, architecture, and natural
features, that were of importance in human events.
These resources consist of (1) physical remains,
(2) areas where significant human events
occurred—even though evidence of the event no
longer remains, and (3) the environment
immediately surrounding the actual resource.
Cultural resources, including both prehistoric and
historic remains, represent a part of the
continuum of events from the earliest evidences of
man to the present day.
Debris Avalanche - Fast moving failures of
shallow, generally cohesionless soils on steep
slopes over an impermeable failure surface.
Debris Torrent - A very fluid mass of soil, rock and
vegetative debris that moves rapidly down steep,
narrow stream channels.
Discharge - Rate of flow of a fluid, the volume of
fluid passing a point per unit of time, commonly
expressed as cubic feet per second (cfs), million
gallons per day, gallons per minute, or cubic
meters per second.
191
Distance Zone - The area that can be seen as
foreground-middleground, background, or
seldom-seen.
Ecosystem - An ecological unit consisting of both
living and nonliving components which interact to
produce a natural, stable system.
Environmental Assessment (EA) - A systematic
environmental analysis of site-specific BLM
activities used to determine whether such
activities have a significant effect on the quality of
the human environment and whether a formal
environmental impact statement is required.
Environmental Impact Statement (EIS) - A formal
document to be filed with the Environmental
Protection Agency that considers significant
environmental impacts expected from
implementation of a major federal action.
Erosion (soil) - Removal of soil from its place of
origin to a point of deposition other than a stream
channel.
Even Flow - Maintaining a relatively constant
undiminishing supply of timber from year to year
for the planning cycle.
Fauna - All the animals in a given area.
Final Harvest Cut - Constitutes removal of a
mature stand, either through clearcutting, the final
stage of a shelterwood regime, or overstory
removal.
Flora - All the plants in a given area.
Forbs - Herbaceous plants; most often used
pertaining to herbaceous plants eaten by wildlife.
Foreground-middleground - The area visible from
a travel route, use area, or other observer position
to a distance not exceeding five miles. The outer
boundary of this zone is defined as the point
where the texture and form of individual plants are
no longer apparent in the landscape. Vegetation is
apparent only in patterns or outline.
Forest Canopy - The more or less continuous
cover of branches and foliage formed collectively
by the crowns of adjacent trees and other woody
growth.
Forest Land - Land that is now, or is capable of
becoming, at least 10 percent stocked with forest
trees and that has not been developed for
nontimber use.
Forest Management Program - Includes timber
activity plan and all forest resource related
program activity plans.
Forest Type Island - An aggregation of trees
occupying a specific area and sufficiently uniform
in composition, age, arrangement and condition to
be distinguishable from vegetation on adjoining
areas.
Groundwater - Subsurface water in the zone of
saturation.
Growing Stock - The amount of standing, green
timber retained to produce forest products; also
known as forest capital.
Habitat - The environment in which an organism
occurs.
High-lead Logging - A cable yarding system in
which lead blocks are hung on a spar or tower to
provide lift to the front end of logs giving partial
suspension.
Historic Resources - All evidences of human
activity that date from historic (i.e., recorded
history) periods. These resources include
documentary data (i.e., written records, archival
material, photographs, maps, etc.), sites, artifacts,
environmental data, and all other relevant
information. Also included are locations where
documented historical events took place, even
though no physical evidence of the events remain
other than the setting. Historic resources are
cultural resources and may be considered
archeological resources when archeological work
is involved in their identification and
interpretation.
Igneous Rock - Rock formed from the cooling and
solidification of molten rock.
Infiltration (soil) - Downward entry of water into
the soil.
Intensive Forest Management Lands - All
commercial forest land that is part of the timber
production base for allowable cut calculation in
the Douglas and South Umpqua Sustained Yield
Units.
Intensive Timber Production Base - Base acreage
intensively managed for timber production using a
50-year minimum harvest age in the allowable cut
computation.
Intermediate Cuttings - Any removal of
merchantable trees from a stand prior to the final
harvest cutting, i.e., commercial thinning,
sanitation/salvage, or shelterwood regeneration
cuttings.
Landing - Any place on or adjacent to the logging
site where logs are assembled for further
transport.
Landscape Features - The land and water form,
vegetation, and structures which compose the
characteristic landscape.
192
Leach - Usually refers to the movement of
chemicals through soil by water; may also refer to
movement of herbicides out of leaves, stems or
roots into the air or soil.
Log Flows - Destinations of harvested timber by
origin. Origins used herein are management units
and counties or county groupings; destinations
are communities, counties or groupings of
counties within which the primary processing of
timber takes place.
Lumber and Wood Products, except Furniture -
Defined by the Office of Management and Budget
and the Standard Industrial Classification Manual
as Major Group #24, which includes logging
contractors engaged in cutting timber and
pulpwoods; merchant sawmills, lath mills, shingle
mills, planing mills, plywood mills, and veneer
mills engaged in producing lumber and wood
basic materials; and establishments engaged in
manufacturing finished articles made entirely or
mainly of wood or wood substitutes. Certain types
of establishments producing wood products are
classified elsewhere, e.g., furniture and office and
store fixtures are classified in Major Group #25.
Management Framework Plan (MFP) - Land use
plan for public lands which provides a set of goals,
objectives, and constraints for a specific planning
area to guide the development of detailed plans
for the management of each resource.
Mass Failure - See Mass Movement.
Mass Movement - Downslope movement of soil
and rock caused by gravity; may be slow (creep)
or rapid (landslide, debris avalanche).
Metamorphic Rock - Rock formed from
preexisting rocks but changed by heat and/or
pressure to rock with new physical, chemical and
mineralogical properties.
Microclimate - The climatic condition of a small
area modified from the general climatic conditions
by local differences in elevation or exposure.
Minimum Harvest Age - The lowest age of a stand
to be scheduled for final harvest.
Mixing Height - The height above the ground
through which vertical mixing of air is relatively
vigorous.
Mortality Salvage - See sanitation/salvage cutting.
Multiple Use - Management of the public lands
and their various resource values so that they are
utilized in the combination that will best meet the
present and future needs of the American people.
National Natural Landmark - Areas designated by
the Secretary of Interior which contain
representative examples of the nation's natural
history, including terrestrial communities, aquatic
communities, landforms, geological features or
habitats of native plant and animal species,
possessing national significance in illustrating or
interpreting the nation's natural heritage.
National Register of Historic Places - The official
list, established by the Historic Preservation Act of
1966, of the Nation's cultural resources worthy of
preservation. The Register lists archeological,
historic, and architectural properties (i.e., districts,
sites, buildings, structures, and objects)
nominated for their local, State, or national
significance by State and/or Federal agencies and
approved by the National Register staff. The
Register is maintained by the National Park
Service.
Natural Levels - Amount of pollutants present
from natural sources without human disturbances
which have reached equilibrium.
Non-commercial Forest Land - Land which is not
capable of yielding at least 20 cubic feet of wood
per acre per year from commercial species, or
land which is capable of producing only non-
commercial tree species.
Non-degradation Policy - Use of the highest and
best practicable treatment and/or control of
wastes, activities and flows to maintain water
quality at the highest possible levels.
Non-forest Land - Land that has been developed
for non-timber uses or land that is incapable of
being 10 percent stocked with forest trees.
Non-point Source Pollution - Pollution caused by
the introduction of materials from diffuse sources
(e.g., sediment, nutrients), or from a natural or
manmade alteration in the stream system.
O&C Lands - Public lands granted to the Oregon
and California Railroad Company and
subsequently revested to the United States.
Old growth - A forest containing many large trees
with large snags and numerous large, down logs.
There is a multi-layered canopy of several species.
Some of the older trees are beginning to show
signs of decadence. Small openings are scattered
throughout the forest. In western Oregon, forests
begin to have old growth characteristics at about
200 years.
Old-Growth Dependent - An animal species so
adapted that it can exist only in old-growth
forests.
Operations Inventory - An intensive forest
inventory which provides managers with
information showing the location, acreage,
silvicultural needs, and mortality-salvage or
thinning needs within each section of public land.
193
Oregon Endangered Species Task Force - An
Interagency task force represented by ODF&W,
USFS, BLM, USF&WS, and Oregon State
University, organized in 1973, to established
habitat management guidelines for Oregon
Endangered Wildlife Species.
Outstanding Natural Areas - Areas of outstanding
scenic splendor, natural wonder or scientific
importance that merit preservation in their natural
condition. The preservation of these resources in
their natural condition is the primary management
objective. Access roads, parking areas and public
use facilities are normally located on the fringe of
the area. The public is encouraged to walk into the
area for recreation purposes wherever feasible.
Paleontology - A science dealing with the life of
past geological periods as known from fossil
remains.
Partial Cutting - Tree removal other than by
clearcutting.
Particulates - Finely divided solid or liquid
particles in the air or in an emission; includes
dust, smoke fumes, mist, spray and fog.
Peak Flow - The highest amount of stream or river
flow occurring in a year or for a single storm
event.
Perched Water Table - The surface of a local zone
of saturation held above the main body of
groundwater by an an impermeable layer or
stratum, usually clay, and separated by the main
body of ground water by an unsaturated zone.
Permeability (soil) - The quality of a soil horizon
that enables water or air to move through it; may
be limited by the presence of one nearly
impermeable horizon even though the others are
permeable.
Personal Income - The income received by all
individuals in the economy from all sources; made
up of wage and salary disbursements, proprietors
income, rental income of persons, dividends,
personal interest income, and the difference
between transfer payments and personal
contributions for social insurance.
Phytoplankton - Suspended, floating or weakly
swimming microscopic aquatic plants.
Plankton - Organisms of relatively small size,
mostly microscopic, that either have relatively
small powers of locomotion or drift in the water
subject to the action of waves and currents.
Plant Community - An association of plants of
various species found growing together in
different areas with similar site characteristics.
Plantation Release - Any action taken on an
established commercial timber stand to control
stand composition and promote dominance
and/or growth of suitable tree species. Treatments
may include mechanical or manual slashing of
undesirable brush and tree species, herbicide,
biological, or a combination of methods. Forest
fertilization is not considered a release treatment.
Plantation Stocking Maintenance - Any vegetation
management action taken on an unestablished
stand to promote the survival and establishment of
suitable trees. Treatments may include using
biological, mechanical, or manual weeding,
mulching, herbicide or a combination of methods.
Precommercial Thinning - Partial cuttings made in
immature stands (10-25 years) in order to
stimulate the growth of remaining trees by making
available increased soil moisture, thereby
increasing total yield from the stand.
Prehistoric - Pertaining to that period of time
before written history.
Progeny Site - A test area for evaluating parent
seed trees by comparing the performance of their
offspring seedlings.
Protection - Any action taken to protect suitable
trees from adverse elements such as weather,
animals, insects, and disease. Treatments include
all practices which increase chances for survival
and normal growth of desired tree species.
Public Lands - Any land and interest in land
owned by the United States within the several
States and administered by the Secretary of the
Interior through the Bureau of Land Management.
May include public domain, O&C or acquired
lands in any combination.
Public Domain Lands - Original holdings of the
United States never granted or conveyed to other
jurisdictions.
Recharge - Process by which water is added to the
zone of saturation, as in recharge of an aquifer.
Recreation Experience Opportunity - The
opportunity for a person to realize predictable
psychological and physiological outcomes from
engaging in a specific recreation activity within a
specific setting.
Recreation Opportunity Setting - Combination of
physical, biological, social, and managerial
attributes present on a particular land area which
influences the experience obtained by engaging in
a specific recreation activity.
Reforestation - Reestablishment of a tree crop on
forest land.
Regeneration - The renewal of a commercial tree
crop, whether by natural or artificial means; also,
the young crop itself.
194
Regeneration Period - The time it takes for a new
commercial timber stand to become stocked
following the date of a timber sale.
Regulated Forest - A forest comprises a desired
(usually even) distribution of age classes or tree
sizes, when the growth equals the cut (at the
highest level sustainable) and when the level of
growing stock remains relatively constant.
Research Natural Areas - Areas established and
maintained for research and education. The
general public may be excluded or restricted
where necessary to protect studies or preserve
research natural areas. Lands may have: (1)
typical or unusual faunistic or floristic types,
associations, or other biotic phenomena, or (2)
characteristic or outstanding geologic, pedologic
or aquatic features or processes.
Riparian Habitat (Area or Zone) - Those terrestrial
areas where the vegetation complex and
microclimate conditions are products of the
combined presence and influence of perennial
and/or intermittent water, associated high water
tables and soils which exhibit some wetness
characteristics.
Runoff - That part of precipitation, as well as any
other flow contributions, which appears in surface
streams, either perennial or intermittent.
Sanitation/Salvage Cutting - Removal of individual
trees killed or injured by fire, insects, disease, etc.,
and the removal of those trees likely to die prior to
final harvest cut so as to utilize merchantable
material.
Sawlog - A log considered suitable in size and
quality for producing sawn timber.
Scenic Quality - The degree (high, moderate, and
low) of visual harmony and variety within a
landscape as compared to other units within the
physiographic region.
Scribner Log Rule - A log rule constructed from
diagrams which shows the number of 1-inch
boards which can be drawn in a circle
representing the small end of a log; assumes a
1/4-inch saw kerf, makes a liberal allowance for
slabs, and disregards taper.
Sediment Yield - The quantity of sediment,
measured in dry weight or by volume, transported
in water flowing through a stream cross-section in
a given time. Consists of both suspended
sediment and bedload.
Sedimentary Rock - A rock formed from materials
deposited from suspension or precipitated from
solution and usually more or less consolidated;
e.g., sandstone, shale, limestone and
conglomerates.
Seldom Seen - Portions of the landscape which
are generally not visible from observer positions,
or areas which are visible beyond 15 miles from
those positions.
Sensitive Species - Species not yet officially listed
but which are undergoing a status review or are
proposed for listing according to Federal Register
notices published by the Secretary of the Interior
or Secretary of Commerce, or according to
comparable State documents published by State
officials. (Reference Instruction Memo W.O.
80-722.)
Sensitivity Level(s) - The degree (high, medium,
low) of user interest in scenic quality and concern
about possible changes in the landscape features
of an area. The two criteria for determining
sensitivity levels are user volumes and user
attitudes.
Serai Stage - The relatively transitory communities
within a sere.
Sere - The whole series of communities which
develop in a given situation.
Shelterwood Cutting - A series of partial cuttings
designed to establish a new crop of trees under
the protection of the old.
Silviculture - The art of producing and tending a
forest.
Siphon - A pipe which uses atmospheric pressure
to transfer water from one point to another against
gravity.
Site Class - A measure of the relative productive
capacity of an area for timber or other vegetation.
Site Preparation - Any action taken in conjunction
with a reforestation effort (natural or artificial) to
create an environment which is favorable for
survival of suitable trees during the first growing
season. This environment can be created by
altering ground cover, soil or microsite conditions,
using biological, mechanical, or manual clearing,
prescribed burning, herbicide or a combination of
methods.
Slash - The branches, bark, tops, cull logs, and
broken or uprooted trees left on the ground after
logging has been completed.
Slump - Rotational failure of a discrete block of
soil on a failure plane that is curved from top to
bottom and from side to side. The block rotates
downward and outward along this failure plane
while remaining more or less intact.
Smolt - A young salmon or trout that is migrating
from freshwater to the ocean.
Snag - A standing dead tree from which the leaves
and most of the limbs have fallen.
195
Soil - The unconsolidated mineral and organic
material on the immediate surface of the earth that
serves as a natural medium for the growth of land
plants.
Soil Mapping Unit - A combination of soils, or
miscellaneous land type or types that can be
shown at the scale of mapping for the defined
purposes of the survey; the basis for the
delineations of a soil survey map.
Soil Productivity - The capacity of a soil in its
normal environment to produce a specified plant
or sequence of plants under a specified system of
management.
Standard Industrial Classification (SIC) - An
industrial classification system as defined by the
Office of Management and Budget; defines
industries in accordance with the composition and
structure of the economy and covers the entire
field of economic activity. Refer to lumber and
wood products for an explanation of SIC 24.
State Historic Preservation Officer (SHPO) - The
official within each State, authorized by the State
at the request of the Secretary of the Interior, to
act as a liaison for purposes of implementing the
National Historic Preservation Act of 1966.
Stream Order - A system of stream classification.
Each small unbranched tributary is a first order
stream. Two first order streams join to make a
second order stream. A third order stream has
only first and second order tributaries, and so
forth.
Subsurface Flow - Horizontal movement of water
through the soil profile.
Succession - The orderly process of plant
community change. Process by which one plant
community will succeed another over time given
the same climatic conditions.
Surplus Inventory - A temporary (1-3 decades)
excess of growing stock over and above that
which is necessary to sustain the even flow level.
Survival Cover - Cover required by animals to
mitigate effects of a period of severe weather that
cannot be met by thermal cover. The objective of
survival cover is to provide a forest stand structure
which will provide shade during times of high
temperatures and intercept snow during severe
storms and provide significant quantities of forage
in the same stand. Stand closure should be at
least 75 percent or more.
Suspended Sediment - Sediment suspended in a
fluid by the upward components of turbulent
currents or by colloidal suspension.
Sustained Yield - The yield that a forest can
produce continuously at a given intensity of
management.
Teratogenicity - Ability of a substance to cause
abnormal development of a fetus.
Texture (soil) - The relative proportion of sand, silt
and clay (expressed as percentages) in a soil;
grouped into standard classes and subclasses in
the USDA Soil Survey Manual.
Thermal Cover - Cover used by animals to
ameliorate effects of weather. For elk, a stand of
conifer trees which are 40 feet or more tall with an
average crown closure of 70 percent or more. For
deer, cover may include saplings, shrubs or trees
at least 5 feet tall with 75 percent crown closure.
Timber Lands - See Forest Land.
Timber Preservation Area - An area withdrawn
from mineral entry and the timber base to protect
the scientific and educational values of timber
resources.
Timber Production Base - Acres included in the
calculation of the allowable cut (see Intensive
Forest Management Lands).
Timber Production Capability Classification
(TPCC) - A classification system that identifies the
commercial forest and base capable of producing
timber on a sustained yield basis.
True Fir - A member of the genus Abies, e.g.,
white fir (Abies concolor). Douglas-fir
(Pseudotsuga menziesii) is not a true fir.
Understory Species - Shade-tolerant plant species
which characteristically grow beneath the forest
canopy; e.g., blackberry and rhododendron.
Unit Resource Analysis (URA) - A BLM planning
document which contains a comprehensive
inventory and analysis of the resources within a
specified geographic area and an analysis of their
potential for development.
Visitor-day - Twelve visitor-hours, which may be
aggregated continuously, intermittently or
simultaneously by one or more persons. Visitor-
days may occur either as recreation visitor-days or
as non-recreation visitor-days.
Visual Resource Basic Elements - The four major
elements (form, line, color, texture) which
determine how the character of a landscape is
perceived.
Visual Resources - The land, water, vegetation,
animals and other features that are visible on all
public lands (scenic values).
Visual Resource Management (VRM) - The
planning, design and implementation of
management objectives to provide acceptable
levels of visual impacts.
196
Visual Resource Management Classes - The
degree of alteration that is acceptable within the
characteristic landscape. Based upon the physical
and sociological characteristics of any given
homogeneous area and serves as a management
objective to mitigate or avoid adverse visual
impacts. Class I provides the highest level of
protection for scenic values, and Class IV the
lowest level.
Volatilize - To evaporate; to change from a liquid
to a gas.
Water Quality - The combined physical, chemical
and biological characteristics of water bodies.
Watershed - The area drained by a given stream.
Wetland or Wetland Habitat - Permanently wet or
intermittently flooded areas where the water table
(fresh, saline, or brackish) is at, near, or above the
soil surface for extended intervals, where hydric
wet soil conditions are normally exhibited, and
where depths generally do not exceed two meters.
Vegetation generally consists of emergent water-
loving forms (hydrophytes) which require at least
a periodically saturated soil condition for growth
and reproduction. In certain instances, vegetation
may be completely lacking.
Wildlife Tree - A live tree remaining after timber
harvest that can become a snag for cavity dwelling
wildlife.
Yarding - The act or process of conveying logs to
a landing.
197
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Index
Criteria (Planning Objectives) 12, 154, 166
Employment 21 , 49, 50, 53, 55, 56, 57, 84, 85, 87
Erosion 20, 29, 30, 61 , 62, 63
Fish Habitat 41 , 42, 74, 75
Fishing 53, 74, 75
Forest Structure 38, 66, 67, 68, 69
Genetically Improved Stock 14, 15, 19, 67
Habitat Corridors 13, 169
Habitat Diversity 1 2, 1 5, 39, 40, 66, 70, 71 , 72, 73, 76
Harvest Levels 3, 4, 12, 13, 14, 15, 16
Herbicides 4, 5, 12, 14, 15, 17, 18, 19, 20, 21, 56, 65, 67, 73, 74, 81
Hunting 53, 70, 71 , 76
Income 50, 51, 53, 55, 56, 57, 84, 85, 86, 87
National Register of Historic Places 1 6, 44, 78, 79
Nationwide Rivers Inventory 23, 43
O&C Revenues 51 , 52, 53, 55, 84, 86, 1 54
Particulates 21 , 28, 60, 61
Sediment Yield 20, 21 , 30, 63, 64, 65, 74
Threatened and Endangered Species 13, 16
Animals 42, 43, 75, 76, 154
Plants 38, 39, 67, 68, 154
Visual Resources 12, 21, 45, 79, 80, 81
Water Yield 63, 64, 65
Wilderness 45, 59
Wildlife Habitat Alteration 21, 68, 69, 70, 71, 72, 73, 74, 179, 180, 181, 182, 183, 184, 185, 186, 187, 188
Bureau of Land Management
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SUSTAINED YIELD UNITS
Roseburg Environmental Impact Statement
1982
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